Memphis Fire Insurance Co. v. Tidwell

OPINION

CHATTIN, Justice.

We will refer to the parties as they appeared in the trial court: that is, Memphis Fire Insurance Company as plaintiff; and George M. Tidwell, Commissioner, as defendant.

*199Defendant, in determining excise taxes owed by plaintiff for the years 1966 through 1969, inclusive, refused to allow a credit on said taxes the amount of taxes paid by plaintiff under T.C.A. Section 56-411, commonly referred to as the Fire Marshal’s Tax.

As a result of the disallowance of the credit, the Department of Revenue assessed additional excise taxes against plaintiff for the years 1966 through…