Woods v. M. J. Kelley Co.

OPINION

HENRY, Justice.

The question before the Court is whether an out-of-state contractor 1 doing business in Tennessee should be liable for a use tax on materials which it caused to be delivered to a construction site in Memphis, where they were installed by labor subcontractors, pursuant to contracts with the out-of-state contractor.

We conclude that the contractor has used these materials in Tennessee in such a manner that it is liable under Sections 67-3001, et seq., T.C.A., for the use tax assessed by the Tennessee Department of Revenue.

I

From May 1973 through March 1975, the appellee, The…