Genesco, Inc. v. Woods

OPINION

HENRY, Chief Justice.

This case involves the amount of interest payable upon a deficiency assessment of excise tax for Genesco’s fiscal years 1963 through 1969, inclusive. More specifically, we deal with a consideration of Chapter 693, Public Acts of 1974, codified as § 67-112, T.C.A.

This section, relating to the imposition of interest on state taxes, provides, in substance, that [except in penalty cases] the Commissioner of Revenue, acting in his discretion, fixes a rate of interest on deficiency assessments between 6% and 8%. Criteria for the establishment of the rate are set out. The…