H. D. Lessors, Inc. v. Tidwell

OPINION

HENRY, Justice.

This action was brought by a Tennessee corporation, seeking to recover excise tax and interest paid under protest, with respect to fiscal years 1968-1970 and 1973. The sole issue presented is the right of the corporation to use the apportionment formula, as contained in § 67-2706, T.C.A., on the basis of its “doing business in Tennessee and elsewhere”. The Chancellor decided adversely to the corporation and we concur in his conclusion.

I

H-D Lessors, Inc. is a Memphis-based Tennessee corporation engaged in the long term leasing of automobiles and trucks, both within and…