Editor's notes.

- In light of the similarity of the statutory provisions, annotations decided under former §§ 14-3-219 and14-3-220 are included in the annotations for this Code Section.

Church property dispute.

- The First Amendment did not prohibit appellate jurisdiction over an action by church members against a pastor and church seeking dissolution of the church, appointment of a receiver, an injunction against the defendant's disposing of corporate assets, and proper disposition of the assets; the dispute was capable of resolution by reference to neutral principles of law, i.e., applicable provisions of the Georgia Nonprofit Corporation Code, without infringing upon any First Amendment values. Crocker v. Stevens, 210 Ga. App. 231, 435 S.E.2d 690 (1993), cert. denied, 511 U.S. 1053, 114 S. Ct. 1613, 128 L. Ed. 2d 340 (1994).

The First Amendment did not preclude an involuntary receivership imposed on a church incorporated under the Georgia Nonprofit Corporation Code. Crocker v. Stevens, 210 Ga. App. 231, 435 S.E.2d 690 (1993), cert. denied, 511 U.S. 1053, 114 S. Ct. 1613, 128 L. Ed. 2d 340 (1994) (decided under former §§ 14-3-219 and14-3-220).

Expenses of liquidators.

- The trial court did not abuse its discretion in refusing to award attorneys fees and expenses of litigation to a church corporation in its defense of a liquidation proceeding considering the amount of compensation awarded to the defendant and the degree to which payment of the church's expenses of litigation from the remainder would frustrate the charitable and religious purposes intended under the corporate charter. Crocker v. Stevens, 210 Ga. App. 231, 435 S.E.2d 690 (1993), cert. denied, 511 U.S. 1053, 114 S. Ct. 1613, 128 L. Ed. 2d 340 (1994) (decided under former § 14-3-220).