Cities Service Co. v. Tidwell

OPINION

FONES, Chief Justice.

Cities Service Company, as plaintiff, sued the Commissioner of Revenue to recover sales taxes, penalty and interest, paid under protest, levied upon engineering, design, procurement and administrative services rendered by Parsons-Jurden Corporation incident to the purchase of industrial machinery from others. Recovery was also sought of penalties assessed upon sales and use taxes, the validity of which is admitted, but, it is said, the equities demand remission of the penalties.

The Chancellor held that the services of Parsons-Jurden Corporation were not subject to…