Vodafone Americas Holdings, Inc. & Subsidiaries v. Richard H. Roberts, Commissioner of Revenue, State of Tennessee

OPINION

HOLLY KIRBY, J.,

delivered the' . opinion of the Court,

in which SHARON - G. LEE, C.J., and CORNELIA A. CLARK and GARY R. WADE, JJ., joined. JEFFREY S. BIVINS, J., filed a depurate opinion, concurring in part and dissenting in part.

In this appeal, we review a tax variance. The Commissioner of Tennessee’s Department of Revenue determined that, if the standard apportionment formula in Tennessee’s franchise and excise tax statutes were applied to the appellant taxpayer, a multistate wireless telecommunications company, nearly all of the taxpayer’s sales receipts for services to its…