Legal Opinion

J.C. Penney National Bank v. Johnson

Court of Appeals of Tennessee

Decided December 17, 1999No. M1998-00497-COA-R3-CVPublishedCited by 32 opinions

1Opinion of the CourtHighers, J.

The J.C. Penney National Bank appeals from the Chancery Court of Davidson County, which upheld the imposition of franchise and excise taxes against the Bank by the Tennessee Department of Revenue. For the reasons stated herein, we reverse the decision of the trial court.

Facts and Procedural History

At all relevant times, the J.C. Penney National Bank 1 (“the National Bank” or “JCPNB”) was a federally chartered national banking association incorporated under the laws of Delaware with its principal place of business and commercial domicile in Harrington, Delaware. Ruth E. Johnson…

2Cases cited14 opinions

  1. International Shoe Co. v. WashingtonSupreme Court of the United States · 1945
  2. Burger King Corp. v. RudzewiczSupreme Court of the United States · 1985
  3. Milliken v. MeyerSupreme Court of the United States · 1941
  4. Complete Auto Transit, Inc. v. BradySupreme Court of the United States · 1977
  5. Quill Corp. v. North Dakota Ex Rel. HeitkampSupreme Court of the United States · 1992

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3Cited by32 opinions

  1. KFC Corporation Vs. Iowa Department Of RevenueSupreme Court of Iowa · 2010
  2. General Motors Corp. v. City of SeattleCourt of Appeals of Washington · 2001
  3. General Motors Corp. v. City of SeattleCourt of Appeals of Washington · 2001
  4. Lamtec Corp. v. Department of RevenueWashington Supreme Court · 2011
  5. Lanco, Inc. v. Director, Division of TaxationSupreme Court of New Jersey · 2006

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