dissenting.
Appellant John Sherman sought a writ of mandamus and injunctive relief against the members of the Fulton County Board of Assessors (“the Board”) and the county’s chief appraiser to compel them to stop what he asserts are illegal tax abatements and preferential tax assessments given in 2006-2009 to several real estate developments that were the subject of bonds issued by the Fulton County Development Authority and validated by the superior court. Mr. Sherman asserts that the Board is not fulfilling its statutory *96duty under OCGA § 48-5-263 (b) to make appraisals of fair market value and comply with rules and regulations established by the tax commissioner for staff duties, and contends that the purported illegal activity is facilitated by the Board’s use of a 50% “ramp-up” formula to value, for ad valorem tax purposes, the leasehold interest held by a real estate developer, the value of which interest has the potential to increase annually as the developer buys back the leased property from the local development authority. See DeKalb County Bd. of Tax Assessors v. W.C. Harris & Co., 248 Ga. 277 (282 SE2d 880) (1981). Acknowledging that OCGA § 36-80-16.1 (e) authorizes the use of the valuation method employed by the Board, Mr. Sherman also contended the statute is unconstitutional. The trial court dismissed Mr. Sherman’s petition and granted judgment on the pleadings to the Board and the chief appraiser. Because I cannot agree with the majority’s decision to reverse the judgment entered by the trial court, I respectfully dissent.
In his petition, Mr. Sherman sought to have the court order the Board to determine the 2009 fair market value of all existing bond transaction leaseholds and reassess them for prior years, and to cease use of the 50% valuation formula. In so doing, Mr. Sherman’s petition takes issue with and seeks judicial reformation of the memoranda of agreement executed years ago in conjunction with each bond transaction by the real estate developer, the Fulton County Development Authority and the Board. Each of those transactions has been the subject of a bond validation proceeding which resulted in the issuance of a judgment of validation. I believe the trial court correctly dismissed Mr. Sherman’s petition because Mr. Sherman may not collaterally attack the judgment of validation that preceded the issuance of bonds for these projects.
[EJven if the judgment of validation is unconstitutional, arguably void, or obtained by fraud, accident, or mistake, it cannot be collaterally attacked ... [t]hat judgment is conclusive as to . . . all other questions which could and should have been asserted and adjudicated during the bond validation proceedings.
Quarterman v. Douglas County Bd. of Commrs., 278 Ga. 363, 365 (602 SE2d 651) (2004). See also Charlton Dev. Auth. v. Charlton County, 253 Ga. 208 (317 SE2d 204) (1984) (conclusiveness of validation proceedings places agreements referred to in the validation judgment beyond challenge); Miller v. Columbus, Georgia, 229 Ga. 234 (190 SE2d 535) (1972) (following the conclusive adjudication of a bond validation proceeding, citizen/taxpayers could not maintain *97an action attacking the conveyance and lease that were adjudicated valid in the bond validation proceeding). The Georgia Constitution requires that there be “incontestable and conclusive” validation of revenue bonds (1983 Ga. Const., Art. IX, Sec. VI, Par. IV), and OCGA § 36-82-78, the legislative implementation of the constitutional requirement, “prevents any collateral attack by the county, county residents, or taxpayers who had proper notice of the validation proceedings but chose not to intervene.” Ambac Indem. Corp. v. Akridge, 262 Ga. 773, 774 (425 SE2d 637) (1993).
The validation scheme provides an easy remedy for every taxpayer, whereby he may have his day in court, without the hazard and risk of seeking the aid of an equity court by injunction.... It provides a speedy and less expensive remedy for the taxpayer. There is no reason, in logic or in law, why the taxpayer should be permitted to decline to enter his appearance and objections in the validation proceeding, allow the decree there to be entered, and then make a formal attack which might have been made in that proceeding.. . .
Gibbs v. City of Social Circle, 191 Ga. 422, 426 (12 SE2d 335) (1940), quoting Love v. Yazoo City, 162 Miss. 65 (138 So. 600, 603) (1932).
The preclusion of collateral attacks on matters that could have been raised in the bond validation proceeding
is necessary to protect the ability of governmental bodies to obtain long-term financing in the bond market. Potential purchasers would be reluctant to invest in the state’s bonds without the assurance that the revenue bonds and their security are not subject to collateral attacks after a court with proper jurisdiction has entered a final validation order. Any perceived risk in the revenue bonds as an investment would impede the ability of state and local governments to finance needed public improvement projects.
Ambac Indem. Corp. v. Akridge, supra, 262 Ga. at 775. The trial court was correct when it dismissed Mr. Sherman’s petition and granted judgment on the pleadings to the Board and chief appraiser. Because the majority authorizes Mr. Sherman to mount a collateral attack on concluded bond validation proceedings that the Georgia Constitution, Georgia statutes, and Georgia jurisprudence prohibit, I respectfully dissent, and I am authorized to state that Chief Justice Hunstein and Justice Thompson join this dissent.
*98Decided November 1, 2010. John F. Woodham, for appellants. Ichter Thomas, Cary Ichter, Patricia A. Roy, S. Renee Huskey, Cheryl M. A. Ringer, Jerolyn W. Ferrari, Robert D. Ware, for appellees. Schiff Hardin, Robert D. Feagin, Han C. Choi, Sandra Z. Zayac, Lewis C. Horne, Jr., Thurbert E. Baker, Attorney General, R. O. Lerer, Deputy Attorney General, Denise E. Whiting-Pack, George S. Zier, Senior Assistant Attorneys General, amici curiae.