Tennessee Farmers' Cooperative v. State ex rel. Jackson

OPINION

DROWOTA, Justice.

This is a direct appeal from the dismissal of a tax refund suit brought pursuant to T.C.A. §§ 16-4-108 and 67-1-901. The Plaintiff is the Tennessee Farmers’ Cooperative, a farm supply cooperative that owns and operates a number of manufacturing facilities in this State. The issue on appeal is whether Plaintiff is entitled to claim the tax rate reduction or tax exemption allowed to manufacturers under T.C.A. § 67-6-206, a provision of the Retailers’ Sales Tax Act, T.C.A. §§ 67-6-101, et seq.

Plaintiff is owned by and services numerous local farm cooperatives and among…