Federal Express Corp. v. Tennessee State Board of Equalization

OPINION

COOPER, Justice.

The application for permission to appeal was granted to review the holding of the Court of Appeals that Federal Express Corporation was not a “public utility” within the definition set forth in T.C.A. § 67-5-501(8), and the concomittant holding that personal property of Federal Express was to be assessed at the 30% commercial and industrial rate rather than the 55% public utility rate.

In 1979, the tax period in question, Federal operated an interstate door-to-door package delivery service, mainly using its own integrated air-ground transportation system of some 80 to 90…