Comdata Network, Inc. v. State Department of Revenue

OPINION

REID, Chief Justice.

This case presents an appeal by Comdata Network, Inc. from the judgment of the trial court granting the Commissioner of Revenue’s motion to dismiss. The record supports the Chancellor’s finding that the Commissioner’s refusal to allow the taxpayer a “credit carryover” for the tax years 1982 through 1984 cannot be asserted pursuant to T.C.A. §§ 67-1-1801 to 67-1-1807 (1989).

The review of this question of law is de novo, with no presumption of correctness for the chancery court’s conclusions of law. See, e.g., Estate of Adkins v. White Consol. Indus., Inc., 788 S.W.2d…