Memphis Dock & Forwarding Co. v. Fort

The complainant is a domestic corporation organized to carry on a warehousing, storage, and freighting business. Its domicile is at Memphis. In 1924 it leased all its buildings, machinery, tracks, and docks to the St. Louis-San Francisco Railway Company for an annual rental that produces a net income.

The commissioner of finance and taxation assessed against complainant the excise tax imposed by law upon corporations. The tax was paid under protest, and this suit followed to recover upon the charge that it was illegally exacted.

The chancellor sustained defendant’s demurrer to the bill, and the…