Barnes, Presiding Judge. The plaintiffs brought this putative class action on behalf of all Fulton County homeowners who purchased their homes in 2015 and 2016, seeking a refund of ad valorem property taxes under OCGA § 48-5-380 from Fulton County and several of its municipalities[1] based on alleged illegal assessments of their properties. In their complaint, as amended, the plaintiffs alleged that the Fulton County Board of Tax Assessors (“Board”) conducted illegal assessments of their properties under state constitutional and statutory law by intentionally singling out their recently sold properties for reappraisal at the increased sales price while leaving the assessed values of comparable unsold properties undisturbed. The trial court subsequently granted the defendants’ motions to dismiss the plaintiffs’ amended complaint for failure to state a claim upon which relief could be granted, concluding that the plaintiffs had failed to state a tax refund claim under OCGA § 48-5-380 and instead should have pursued a tax appeal under a different statute. The plaintiffs now appeal from the trial court’s dismissal order. For the reasons discussed more fully below, we reverse. We review de novo a trial court’s grant of a motion to dismiss for failure to state a claim upon which relief can be granted. Southstar Energy Svcs. v. Ellison, 286 Ga. 709, 710 (1) (691 SE2d 203) (2010). Under OCGA § 9-11-12 (b) (6), a motion to dismiss for failure to state a claim upon which relief can be granted should not be sustained unless (1) the allegations of the complaint disclose with certainty that the claimant would not be entitled to relief under any state of provable facts asserted in support thereof; and (2) the movant establishes that the claimant could not possibly introduce evidence within the framework of the complaint sufficient to warrant a grant of the relief sought. In deciding a motion to dismiss, all pleadings are to be construed most favorably to the party who filed them, and all doubts regarding such pleadings must be resolved in the filing party’s favor. (Citation and punctuation omitted.) Renton v. Watson, 319 Ga. App. 896, 897 (739 SE2d 19) (2013). See Northway v. Allen, 291 Ga. 227, 229 (728 SE2d 624) (2012). Guided by these principles, we turn to the plaintiffs’ amended complaint, which alleged as follows. The Board assesses all real property located in Fulton County, and those assessments are then used by the defendants to generate tax bills for property owners. The named plaintiffs and putative class members are homeowners who purchased real property in Fulton County in 2015 or 2016. The plaintiffs paid property taxes in 2016 and 2017 based on assessments of their properties by the Board that the plaintiffs allege were illegal. More specifically, the amended complaint alleged that the Board, in assessing the fair market values of the plaintiffs’ properties for the 2016 and 2017 tax years, did not follow its customary appraisal methodology and instead increased the assessed value of the plaintiffs’ properties to equal the sales prices from 2015 or 2016. According to the amended complaint, except in “rare instances,” the Board did not reassess the values of comparable residential properties that had not been sold. The amended complaint further alleged that, as a result of the Board’s divergent treatment of sold and unsold properties, the plaintiffs were required to pay property taxes to the defendants for the tax years of 2016 and 2017 that were significantly higher than the taxes paid by owners of similarly situated residential properties that did not sell in 2015 or 2016. In 2018, the plaintiffs filed their putative class action complaint against Fulton County seeking property tax refunds pursuant to OCGA § 48-5-380.[2] The plaintiffs thereafter twice amended their complaint and added additional plaintiffs and several municipalities within Fulton County as defendants. The plaintiffs alleged in their complaint, as amended, that by appraising their properties in 2016 and 2017 based on sales price without reappraising similarly situated residential properties that had not been sold in 2015 and 2016, the Board violated the Uniformity Clause of the Georgia Constitution,[3] the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution, and the equalization requirement imposed by OCGA § 48-5-306 (a).[4] Consequently, the plaintiffs alleged that they were due refunds from the defendants of the taxes illegally assessed in 2016 and 2017, in addition to pre- and post-judgment interest and attorney fees and expenses under OCGA § 13-6-11. The defendants moved to dismiss the plaintiffs’ amended complaint, asserting that the plaintiffs had failed to state a claim for a tax refund under OCGA § 48-5-380. According to the defendants, the plaintiffs were limited to challenging the Board’s actions through the tax appeal process set out in OCGA § 48-5-311, which the plaintiffs had failed to do.[5] Following a hearing, the trial court granted the defendants’ motions to dismiss in April 2020. The trial court concluded that the facts as alleged in the amended complaint failed to state a cognizable claim for an illegal assessment of the plaintiffs’ properties so as to bring the claim within the ambit of the tax refund statute, OCGA § 48-5-380.[6] The trial court further concluded that the gravamen of the plaintiffs’ allegations was that the Board, in assessing the value of their properties for the 2016 and 2017 tax years, had failed to consider other factors beyond the recent sale price, and the court ruled that such a claim could only be pursued through the tax appeal process set forth in OCGA § 48-5-311. On appeal from the dismissal order, the plaintiffs argue that the trial court erred in holding that their complaint failed to state a claim for a tax refund under OCGA § 48-5-380 and that they thus were limited to pursuing a tax appeal under OCGA § 48-5-311. We agree. Taxpayers generally have two avenues for challenging an improper tax assessment: (1) the appeal process in OCGA § 48-5-311, and (2) the refund procedure in OCGA § 48-5-380. These distinct remedies, however, serve different purposes. An appeal under OCGA § 48-5-311 provides the most expeditious resolution of a taxpayer’s dissatisfaction with an assessment, preferably before taxes are paid. In contrast, an OCGA § 48-5-380 refund action . . . [provides a ] procedure to protect taxpayers from later-discovered defects in the assessment process which have resulted in taxes being erroneously or illegally assessed and collected. (Citation and punctuation omitted.) Slivka v. Nelson, 328 Ga. App. 468, 470 (1) (762 SE2d 162) (2014). In distinguishing between OCGA § 48-5-311 and OCGA § 48-5-380, our Supreme Court has held that [a]lthough a taxpayer may raise issues of valuation, uniformity, and equalization under both statutes, . . . the taxpayer should assert any error in the assessment of the real property in an appeal proceeding under § 48-5-311 whereas the refund action under § 48-5-380 is reserved for claims of factual or legal error that have resulted in erroneous or illegal taxation. Nat. Health Network v. Fulton County, 270 Ga. 724, 726 (1) (514 SE2d 422) (1999). See Gwinnett County v. Gwinnett I L.P., 265 Ga. 645, 646-647 (458 SE2d 632) (1995). To determine whether a claim can be brought as a tax refund claim under OCGA § 48-5-380, courts must look “not [at] the general nature of the ground asserted, but the underlying facts supporting the asserted ground.” Gwinnett County, 265 Ga. at 647. In this regard, [a] claim based on mere dissatisfaction with an assessment, or on an assertion that the assessors, although using correct procedures, did not take into account matters which the taxpayer believes should have been considered (e.g., different comparable sales for the purpose of establishing value), is not . . . one which asserts that an assessment is erroneous or illegal within the meaning of § 48-5-380. Id. In contrast, “[i]f the taxpayer alleges that the assessment is based on matters of fact in the record which are inaccurate, or that the assessment was reached by the use of illegal procedures, then the taxpayer has asserted a claim that the taxes were ‘erroneously or illegally assessed and collected’” under OCGA § 48-5-380. Id. Furthermore, in Nat. Health Network, 270 Ga. at 727 (2), the Supreme Court pointed out that an “illegal” tax assessment that can be pursued under OCGA § 48-5-380 includes the circumstance where “a taxing authority assessed and collected taxes in violation of federal or state law.” (Footnotes omitted.) And, as an example of such a circumstance, the Supreme Court cited to Griggs v. Greene, 230 Ga. 257, 266 (3) (197 SE2d 116) (1973),[7] a case from that Court holding that the Uniformity Clause had been violated when county tax digests were adjusted by impermissibly raising assessments according to sub-classes of property. See Nat. Health Network, 270 Ga. at 727 (2), n. 20. Here, in their amended complaint, the plaintiffs did not simply express dissatisfaction with the assessed value of their properties or, as suggested by the trial court, merely allege that the Board, using correct procedures, failed to take into account other factors that should have been considered as part of the assessments. Compare Trans Link Motor Express v. Dougherty County, 265 Ga. App. 10, 12 (592 SE2d 859) (2003) (taxpayer could not pursue tax refund claim under OCGA § 48-5-380 based on allegation that county collected the wrong amount of taxes because it failed to take into account interstate mileage as part of tax assessment); Parian Lodge v. DeKalb County, 225 Ga. App. 853, 855 (1) (485 SE2d 545) (1997) (plaintiff could not pursue tax refund claim under OCGA § 48-5-380 where plaintiff “merely asserts that the 1991 assessed value [of the property] established the fair market value of the property in 1990″). Rather, viewed most favorably to the plaintiffs, the amended complaint alleged that the Board engaged in “sales chasing”[8] by selectively targeting recently sold properties for reappraisal at the increased sales price while leaving the assessed values of similarly situated unsold properties unchanged. See generally Callaway v. Carswell, 240 Ga. 579, 583 (2) (242 SE2d 103) (1978) (noting that question of whether county “could reassess property piecemeal” was different from question regarding valuation of the taxpayers’ property). According to the amended complaint, such a procedure, predicated on the intentional targeting of a subclass of property owners for increased assessments and taken without regard to establishing uniformity and equalization between taxpayers with like properties, violates the Uniformity Clause of the Georgia Constitution and the equalization requirement imposed by OCGA § 48-5-306 (a). We cannot say that within the framework of the amended complaint, the plaintiffs would be unable to come forward with evidence that the Board used an illegal procedure and violated state law in its assessment of the plaintiffs’ properties for the 2016 and 2017 tax years. See Champion Papers v. Williams, 221 Ga. 345, 346 (144 SE2d 514) (1965) (holding that “attempt to increase revenue by arbitrary and discriminatory assessments against one group of taxpayers without consideration of an increase for all others” violated well established rule that the “[t]axation of all kinds of property of the same class must be uniform and by the same standard of valuation, equally with other taxable property of the same class”); Dade County v. Eldridge, 229 Ga. App. 401, 401 (494 SE2d 106) (1997) (concluding that “it is illegal for a taxing authority simply to pick and choose particular pieces of property to assess and reassess without regard to uniformity, proportionality and equalization among properties of the same class”).[9] Indeed, courts from several other jurisdictions have concluded that selective reappraisals and sales chasing are illegal and violate the principle of uniformity.[10] Contrary to the conclusion reached by the trial court, the plaintiffs stated a claim under the tax refund statute, OCGA § 48-5-380. In reaching this conclusion, we are mindful that our Supreme Court has held that “county boards of tax assessors are not required to use any particular appraisal approach or method when determining the fair market value of property for purposes of ad valorem taxation.” Sherman v. Fulton County Bd. of Assessors, 288 Ga. 88, 91 (701 SE2d 472) (2010). Our Supreme Court also has held that “the utilization of different methods to determine fair market value does not contravene the Constitution or the laws of Georgia” and has noted, as an example, that “real property recently sold may be valued at sales price, while other property is valued by comparable sales.” Dougherty County Bd. of Tax Assessors v. Burt Realty Co., 250 Ga. 467, 469 (298 SE2d 475) (1983). Additionally, Georgia’s tax statutes and regulations contemplate that the recent sales price of a property may be used to determine its fair market value for tax assessment purposes under certain circumstances. See OCGA § 48-5-2 (3);[11] Ga. Comp. R. & Regs. r. 5601110.09 (4) (b) (1) (i).
