Carson Creek Vacation Resorts, Inc. v. State, Department of Revenue

OPINION

O’BRIEN, Justice.

This case originated in the Chancery Court of Cocke County. The State Department of Revenue assessed sales taxes against Carson Creek Vacation Resort in the amount of $32,-261 for the period beginning 11 August 1984 through December 1986. The Department based the assessment upon membership fees charged by Carson Creek to its patrons for the use of the resort’s campground facilities. Carson Creek paid the assessed tax and interest and, thereafter, filed a complaint for a refund in the Chancery Court.

At trial, the chancellor determined that the sale of resort memberships…