Federal Express Corp. v. Woods

OPINION

HENRY, Chief Justice.

This action, brought pursuant to Section 67-2301, T.C.A., et seq., seeks to recover $117,125.55 in use taxes and interest paid under protest. Federal Express Corporation, an interstate air carrier, takes the position that its use of aircraft parts and materials on which the tax was assessed is exempt from taxation under Section 67-3012, T.C.A. Federal Express does not contest the State’s right or power to levy the tax. The sole issue facing this Court is whether appellant is entitled to the statutory exemption.

I

Federal Express is a Delaware corporation with its…