dissenting.
I respectfully dissent.
1. The trial court, on an undisputed evidentiary record by agreement of the parties, tried all of the issues in the case on the merits and entered a final declaratory judgment on the merits, which was adverse to the plaintiffs. OCGA § 9-11-65 (a) (2). Having decided the issues adversely to the plaintiffs as a matter of law, injunctive relief in equity was not appropriate. The legal questions were simple: (1) did the ballot language of the referendum determine when the SPLOST terminated or (2) did the statute authorizing the SPLOST provide the termination date?
Carroll County, through the State Revenue Commissioner, can collect a SPLOST or any other tax authorized by the Georgia Constitution or by law authorized under the Constitution. “A County can only exercise the power of taxation as conferred upon it either directly by the Constitution or by the General Assembly when authorized by the Constitution.” (Citation and punctuation omitted.) Cha-nin v. Bibb County, 234 Ga. 282, 286 (216 SE2d 250) (1975); accord DeKalb County v. Brown Builders Co., 227 Ga. 777, 778 (2) (183 SE2d' 367) (1971); Richmond County Business Assn. v. Richmond County, 224 Ga. 854, 856 (165 SE2d 293) (1968); Commrs. of Chatham County v. Savannah Elec. &c. Co., 215 Ga. 636, 637 (112 SE2d 655) (1960); Ga. Const, of 1983, Art. VII, Sec. I, Par. I; Art. IX, Sec. IV, Par. I. However, the tax imposed here was not under local ordinance, but under an act of the General Assembly, and was administered on behalf of the county and municipalities by the State Revenue Commissioner as a county tax.
In regard to the prescribed language of the referendum,
[t]he formula prescribed by the legislature was not intended *198for the purpose of informing the voter as to the full contents of the [statute]. On the contrary, the formula was intended as the declaration by the voter of his approval or disapproval of the [SPLOST referendum,] which had been published [countywide]. The [SPLOST referendum] was submitted to the elector, and the formula prescribed was simply to elicit his expression as to whether or not the proposed [SPLOST] should become a part of the [county taxes]. The formula written or printed on his ballot was but the legislative means of obtaining his expression upon the published proposal; and when he adopted the formula he indicated his vote upon the whole [SPLOST] which was submitted, and not a mere part. [Cit.]
(Punctuation omitted.) McLennan v. Aldredge, 223 Ga. 879, 882 (1) (159 SE2d 682) (1968).
A referendum of the electorate consenting to a specific tax imposition is neither a law nor a constitutional authorization to tax; it confers no power to tax, in and of itself, but is merely a precondition. McLennan v. Aldredge, supra at 882. Such referendum vote by a majority of the electorate to the imposition of a SPLOST is the exercise of a condition precedent to impose a tax authorized by the constitution and by the General Assembly conditioned upon such prior consent, which can be conferred at any time. Bd. of Commrs. of Taylor County v. Cooper, 245 Ga. 251, 258-259 (4) (264 SE2d 193) (1980). The power to tax comes not from the referendum, but from the General Assembly by statute authorized by the constitution. Id. Therefore, the electorate can either agree or disagree to be taxed under the terms and conditions of the statutory authority, not the ballot. Once a referendum is conducted, such correct record and return of the vote are transmitted to the State Revenue Commissioner. OCGA § 48-8-111; see generally Gwinnett County v. Bolin, 262 Ga. 67, 69 (414 SE2d 225) (1992).
The descriptive caption to Ga. L. 1987, p. 1322, reads in part that its purpose is “to change provisions relating to the termination of the tax.” Thus, in passing the enabling legislation to create a SPLOST, the General Assembly expressed the clear intent to set the termination date by the statute and not by the language of the referendum ballot. Ga. L. 1987, pp. 1322, 1329-1330, § 2; OCGA § 48-8-112. The General Assembly amended this act in Ga. L. 1992, pp. 2998, 3001, § 1, to provide that in the proposed ordinance the termination dates of such taxes were
[flour years for roads, street, and bridge purposes and five years for purposes other than road, street, and bridge pur*199poses if the proceeds of the tax are to be used in part for road, street, and bridge purposes and in part for purposes other than road, street, and bridge purposes for which the tax may be imposed.
OCGA § 48-8-111 (a) (2), which fixed the termination date under OCGA § 48-8-112 (b) (2) by passage of time only. When read in pari materia with Ga. L. 1985, pp. 232, 237-238, § 1 (OCGA § 48-8-112 (b) (2) and (3)), all combined purposes, as in this case, terminated “[o]n the final day of the maximum period of time specified for the imposition of the tax,” i.e., five years. Ga. L. 1992, pp. 2998, 3001, § 1 (OCGA § 48-8-111 (a) (2)). In contrast, where the purpose did not include a combination of roads, streets, and bridges and other purposes, i.e., “mixed purpose,” the termination date was “as of the end of the calendar quarter during which the commissioner determines that the tax will have raised revenues sufficient to provide to the county net proceeds equal to or greater than the amount specified as the maximum cost of the project.” Ga. L. 1985, pp. 232, 238, § 1 (OCGA § 48-8-112 (b) (3)). Clearly and unambiguously, the statutes provided that a combined or mixed purpose SPLOST terminated based upon time and not based upon maximum tax receipts. Such termination provisions were clear and unambiguous whether for a single or mixed use purpose contrary to the majority’s position; there was no “gap” for mixed use SPLOST. See Ga. L. 1985, pp. 232, 238, § 1; Ga. L. 1992, pp. 2998, 3001, § 1.
However, Ga. L. 1997, p. 519, § 1 changed the termination date again and provided under Code section 48-8-112 (b) (3) that the language “[i]f the tax was imposed other than for road, street, and bridge purposes” was removed so that such subsection now applied to all purposes, whether road, non-road, or combined. Further, in § 2 of that 1997 amendment, the General Assembly limited such provision to prospective application only;
[notwithstanding any provision of Code Section 1-3-4.1 to the contrary, this Act shall become effective upon its approval by the Governor or upon its becoming law without such approval and shall apply with respect to taxes imposed or to be imposed under resolutions or ordinances adopted on or after said effective date.
(Emphasis supplied.) Ga. L. 1997, pp. 519, 520, § 2. Therefore, such amendment does not retroactively apply to the Carroll County SPLOST. In fact, the necessity of passing such amendment, which would bring about the result that plaintiffs urge if applied retrospectively, indicates that the General Assembly believed that the prior *200statutory provisions, rather than the formula prescribed by the ballot, determined the date of termination.
Further, former OCGA § 48-8-112 (b) (2) provided that the tax would terminate “[o]n the final day of the maximum period of time specified for the imposition of the tax,” which was five years. Ga. L. 1987, p. 1322, § 2. Under OCGA § 48-8-112 (b) (2), the Revenue Commissioner is under a statutory mandate to collect such tax until the termination date on March 31, 1999, five years after imposition. See generally Cellular One v. Emanuel County, 227 Ga. App. 197, 198-199 (489 SE2d 50) (1997).
The Supreme Court of Georgia, speaking of the ballot language for a constitutional amendment, stated, “we hold that the ballot language is not a proper subject for more than this minimal judicial review,” because such ballot language is only to sufficiently inform the elector of the nature of the matter to be voted on in the referendum. Sears v. State of Ga., 232 Ga. 547, 555-556 (4) (208 SE2d 93) (1974); see also Goldrush II v. City of Marietta, 267 Ga. 683, 686 (2) (b) (482 SE2d 347) (1997); Donaldson v. Dept. of Transp., 262 Ga. 49, 51 (1) (414 SE2d 638) (1992); Carter v. Burson, 230 Ga. 511, 521-522 (5) (198 SE2d 151) (1973).
It was within legislative discretion to adopt some formula by which the voter would express his assent or dissent to the [SPLOST].... The formula written or printed on his ballot was but the legislative means of obtaining his expression upon the published proposal.
Cooney v. Foote, 142 Ga. 647, 654-655 (3) (83 SE 537) (1914); accord Carter v. Burson, supra at 522. The General Assembly, unlike Congress, has original and not delegated powers, which power is limited only by the state and federal constitutions. Sears v. State of Ga., supra at 554.
The inherent powers of our State General Assembly are awesome [, and it] is entrusted with the general authority to make laws at discretion. This is true of the Georgia Legislature, the legislature being within the pale of its constitutional competency, the paramount and sovereign power in the State, clothed by the people with all power except where they have made limitations. The legislature is absolutely unrestricted in its power to legislate, so long as it does not undertake to enact measures prohibited by the State and Federal Constitution.
(Citations and punctuation omitted.) Id. at 553-554. Thus, the General Assembly had the power to establish the termination date of a *201SPLOST by statute regardless of the ballot language.
There was nothing ambiguous in the statute or its amendments regarding the termination date for a mixed purpose SPLOST. Since this was a combination of purposes project within the plain language of Ga. L. 1992, pp. 2998, 2999, 3001, § 1, OCGA § 48-8-111 (a) (1) (D) and (H) (2), and Ga. L. 1987, pp. 1322, 1329-1330, § 2, OCGA § 48-8-112 (b) (2), then the termination date was at the end of five years, which would be March 31, 1999. Where, as here, the language of the statute is plain and unequivocal, judicial construction is not only unnecessary but is prohibited. City of Jesup v. Bennett, 226 Ga. 606 (176 SE2d 81) (1970); Thompson v. Ga. Power Co., 73 Ga. App. 587 (37 SE2d 622) (1946). The majority seeks to find ambiguity where there is none and fails to follow the rules of statutory construction. OCGA § 1-3-1 (a).
Thus, where the validity of a tax act is questioned, declaratory judgment is appropriate. See Camp v. MARTA, 229 Ga. 35, 36 (189 SE2d 56) (1972); Martin v. Ellis, 242 Ga. 340, 342 (249 SE2d 23) (1978). Since the trial court entered a final declaratory judgment on the merits adverse to the plaintiffs, then plaintiffs had an adequate remedy at law and were not entitled to injunctive relief. Camp v. MARTA, supra at 36; Martin v. Ellis, supra at 342; see also OCGA §§ 23-1-3; 23-1-4; Cantrell v. Henry County, 250 Ga. 822 (301 SE2d 870) (1983). Further, if equity jurisdiction did, in fact, exist and since the judgment was adverse to plaintiffs, then the trial court determined as a matter of public policy and balancing of the equities that plaintiffs were not entitled to an injunction. Ledbetter Bros., Inc. v. Floyd County, 237 Ga. 22 (226 SE2d 730) (1976); Bradley v. Roberts, 233 Ga. 114 (210 SE2d 236) (1974); Milton Frank Allen Publications v. Ga. Assn, of Petroleum Retailers, 223 Ga. 784, 788 (158 SE2d 248) (1967).
2. At the agreed upon hearing on the merits, plaintiffs raised for the first time Counts 4, 5, and 6 by filing an amended complaint. Plaintiffs agreed to proceed with the trial of all issues and failed to object, request a continuance, or request to submit evidence after the hearing. Therefore, any objection to consideration of such issues was not preserved for appeal. Plaintiffs never raised a constitutional issue as to notice that they must try such issues and present any evidence at the final hearing.
Further, such constitutional. issues have not been properly framed, as follows: (1) the constitutional issues were not raised in writing in the trial court; (2) they were not specifically or with fair precision set forth as to which constitutional rights were implicated and in what way such rights were violated by the particular portion of the statute to raise a justiciable issue ripe for determination; (3) plaintiffs did not demonstrate standing; (4) such issues were not *202raised at the earliest opportunity; and (5) the trial court has not passed upon such constitutional issues. Thus, such issues are not ripe for review. Marchman & Marchman, Inc. v. City of Atlanta, 250 Ga. 64 (295 SE2d 311) (1982); St. John’s Melkite Catholic Church v. Commr. of Revenue, 240 Ga. 733, 734 (1) (242 SE2d 108) (1978); Richmond Concrete Products Co. v. Ward, 212 Ga. 773, 774-775 (95 SE2d 677) (1956), overruled on other grounds, State of Ga. v. Crane, 224 Ga. 643, 644 (164 SE2d 116) (1968).
Further, plaintiffs have waived or abandoned such issues under Court of Appeals Rule 27 (c) by failing to specifically reference the record or transcript regarding such enumerated errors. See Henry v. Med. Center, 216 Ga. App. 893, 894 (1) (456 SE2d 216) (1995); Dugger v. Danello, 175 Ga. App. 618, 620 (2) (334 SE2d 3) (1985).
3. Counts 4, 5, and 6 of the complaint sought injunctive relief in equity to impound the taxes collected after March 1998 and to compel the keeping of records as to such tax receipts and expenditures. An action for injunctive relief is to immediately prevent, stop, or reverse conduct causing irreparable harm. Therefore, it is an action to proceed in court without normal discovery to a temporary or interlocutory evidentiary hearing or an accelerated final hearing. OCGA § 9-11-65 (a) (2). Because such hearing is accelerated, the rules of evidence are relaxed.
Further, neither OCGA § 9-11-26 nor Uniform Superior Court Rule 5 grants parties any specified time for discovery to be conducted; the length of discovery rests in the sound discretion of the trial court. USCR 5.1 states:
[i]n order for a party to utilize the court’s compulsory process to compel discovery, any desired discovery procedures must first be commenced promptly, pursued diligently and completed without unnecessary delay and within six months after the filing of the answer. At any time, the court, in its discretion, may extend, reopen or shorten the time to utilize the court’s compulsory process to compel discovery.
Thus, there is no specified time within which to conduct discovery, only a limitation on the period that the trial court will enforce discovery; by trial court order, discovery can be shortened or increased. Alexander v. Macon-Bibb County Urban Dev. Auth., 257 Ga. 181, 184 (5) (357 SE2d 62) (1987); Walton v. Datry, 185 Ga. App. 88, 90 (1) (363 SE2d 295) (1987).
A trial court has wide discretion to shorten, extend, or reopen the time for discovery, and its decision will not be reversed unless a clear abuse of that discretion is shown. Stewart v. *203Stewart, 260 Ga. 812, 813 (400 SE2d 622) (1991); Ambassador College v. Goetzke, 244 Ga. 322 (260 SE2d 27) (1979), cert, denied, 444 U. S. 1079 (100 SC 1029, 62 LE2d 762) (1980).Decided July 16, 1999 Gary P. Bunch, for appellants. Thurbert E. Baker, Attorney General, Daniel M. Formby, Deputy Attorney General, David A. Runnion, Warren R. Calvert, Senior Assistant Attorneys General, David A. Basil, for appellees.
Woelper v. Piedmont Cotton Mills, 266 Ga. 472, 473 (1) (467 SE2d 517) (1996).
The record shows that the parties agreed to proceed without discovery and the trial court required the evidence be produced or stipulated by the defendants in lieu of discovery so that these important public policy issues could be tried on the merits at the earliest date. Plaintiffs agreed to the factual stipulations and placed additional evidence into the record after the hearing. Plaintiffs made no objection in the trial court or attempt to engage in any discovery. Therefore, there is no evidence of an abuse of the trial court’s discretion.