Trailer Conditioners, Inc. v. Huddleston

OPINION

CANTRELL, Judge.

The Chancery Court of Davidson County ordered the Tennessee Commissioner of Revenue to refund $669,789 that appellee Trailer Conditioners, Inc. paid as sales taxes on services performed between December 1987 and June 1991 for its parent company. The Commissioner of Revenue appealed the order of the Chancery Court, contending that the appellee was properly taxable under Tennessee’s Sales and Use Tax Statutes. We find that the Commissioner was correct, and we reverse the order of the trial court.

I

Trailer Conditioners, Inc. (TCI) is a wholly-owned subsidiary of United…