Beaty Trust Co. v. South Carolina Tax Commission

I would affirm the order of the trial judge; therefore, I respectfully dissent.

Reliance by the majority on the case of Textron, Inc. v. Livingston, 244 S. C. 380, 137 S. E. (2d) 267 (1964) is, in my view, misplaced. Upon examination, it is clearly distinguishable. In that case, Textron, Inc. contracted with Daniel Construction Co., Inc. to build a plant in South Carolina. Daniel Construction Company, Inc. purchased the plant site and constructed the building. After completion, instead of taking title as owner, Textron had Daniel convey title to the Annuity Board of the Southern Baptist…