...County Atty., DeKalb County Law Department, Decatur, for Tom Scott, Tax Comr. Marvin P. Nodvin, The Nodvin Firm, LLC, Atlanta, for Lombard Corporation et al. BENHAM, Chief Justice. This case began in the trial court as a constitutional challenge to OCGA § 48-6-20 et seq., Georgia's intangible personal property tax statute, but has become an appeal concerning the doctrine of mootness in Georgia law....

...986 when, upon the advice of an attorney in the Law Department, Home Depot was removed from the domesti*71cated list for intangible tax purposes. The General Assembly, in rapid response to the commissioner’s change in interpretation, amended OCGA § 48-6-20 to clarify the legislative intent to continue to allow the shares of those corporations that had incorporated out of state but that maintained their corporate headquarters in Georgia an exemption from the intangible tax....

...time in the Revenue and Taxation Code as follows: A foreign corporation which has procured a certificate of authority to transact business in this state from the Secretary of State and which maintains its corporate headquarters in this state. OCGA § 48-6-20 (3.1) (B). 1....

...The Georgia Business Corporation Code does not control the legislative intent with regard to whether or not a corporation is a “domesticated foreign corporation” for the purposes of the Revenue and Taxation Code. The revenue commissioner acknowledges that as of the effective date of OCGA § 48-6-20 the shareholders are entitled to the exemption, but insists on collecting the intangible taxes during the “window-in-time” after he changed his interpretation and before the effective date of the clarification. 2....