Hoyer-Schlesinger-Turner, Inc. v. Benson

OPINION

DYER, Chief Justice.

This is a suit by the taxpayer, Hoyer-Schlesinger-Turner, Inc., (herein referred to as HST), to recover sales and use tax paid under protest. The chancellor found HST liable for the taxes and dismissed the bill, resulting in this appeal.

HST entered into contracts with Velsicol Chemical Corporation to design and construct three chemical manufacturing systems in Memphis, Tennessee. HST applied for and was granted permits by ap-pellee, Thomas D. Benson, Commissioner of Revenue for the State of Tennessee, to purchase the personal property needed to fulfill these…