Legal Opinion

SAP America, Inc. v. David Gerregano, Commissioner of Revenue, State of Tennessee

Court of Appeals of Tennessee

Decided May 13, 2026No. M2024-01399-COA-R3-CVPublished

1Opinion of the Court

05/13/2026 IN THE COURT OF APPEALS OF TENNESSEE AT NASHVILLE August 6, 2025 Session SAP AMERICA, INC. V. DAVID GERREGANO, COMMISSIONER OF REVENUE, STATE OF TENNESSEE Appeal from the Chancery Court for Davidson County No. 20-1249-II Anne C. Martin, Chancellor No. M2024-01399-COA-R3-CV The Tennessee Department of Revenue issued a business tax assessment against a company based on the company’s gross receipts from sales of computer software, cloud hosting, and cloud-based services. The company challenged the assessment by filing a complaint in the chancery court. Both parties filed motions for…

2Cases cited16 opinions

  1. Byrd v. HallTennessee Supreme Court · 1993
  2. Michelle RYE Et Al. v. WOMEN’S CARE CENTER OF MEMPHIS, MPLLC Et Al.Tennessee Supreme Court · 2015
  3. Tennie Martin, et.al. v. Southern Railway Company, et.al.Tennessee Supreme Court · 2008
  4. McCarley v. West Quality Food ServiceTennessee Supreme Court · 1998
  5. Godfrey v. RuizTennessee Supreme Court · 2002

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