Cordis Corp. v. Taylor

OPINION

COOPER, Justice.

This is an appeal by the Commissioner of Revenue of the State of Tennessee from a decree of the Chancery Court of Davidson County, ordering a refund of sales taxes paid under protest.

The parties stipulated that Cordis sold implantable cardiac pacemakers and hydrocephalus valve systems in the State of Tennessee during the taxable years in question. Cordis did not collect or pay the Tennessee sales tax on the sales on the ground that the devices sold were exempt from sales tax under T.C.A. § 67-6-314(5), which exempts from tax the “sale of pros-thetics, orthotics, special…