At & T CORP. v. Rylander

J. WOODFIN JONES, Justice.

Appellants AT & T Corporation (“AT & T”) and AT & T Communications of the Southwest, Inc. (“AT & T Southwest”) 1 sued the State Comptroller, appellee, 2 after the Comptroller denied the AT & T Companies’ request for a refund of certain taxes paid. Following a bench trial, the trial court rendered judgment for the Comptroller. We will affirm.

FACTUAL AND PROCEDURAL BACKGROUND

The material facts in this case are largely undisputed. Appellants AT & T and its wholly owned subsidiary AT & T Southwest are two distinct taxpayers that are, or have been, in the business of…