Kroger Co. v. Tollett

OPINION

HARBISON, Justice.

This case involves the interpretation and application of a state privilege tax contained in T.C.A. § 67 — 4102 Item B, entitled:

“Bottlers and manufacturers of soft drinks and substitutes therefor.”

The words “and substitutes therefor” were added to the title of the code section in the revision of the statute contained in 1963 Tennessee Public Acts, chapter 35. They are, in our opinion, of significance in ascertaining the legislative intent.

The taxpayer in this case, The Kroger Company, is neither a bottler nor a manufacturer of soft drinks but is one of the…