Intangible recording tax is due on the entire face amount of a security instrument securing a "wrap-around" note which is otherwise a long-term note secured by real estate. This type of transaction is not a modification by extension, transfer, assignment, or renewal as defined in Revenue Rule 560-11-8-.04 above and does not fall within the provisions of Revenue Rule 560-11-8-.04 since there is a new lender.
Ga. Comp. R. & Regs. R. 560-11-8-.09
O.C.G.A. Secs. 48-6-60 - 48-6-77.