Cook Export Corp. v. King

*880OPINION

HARBISON, Chief Justice.

In this action Cook Export Corporation, a wholly owned corporate subsidiary of Cook Industries, Inc., seeks refund of corporate excise and franchise taxes for the years 1972 and 1973. During those years it did business in no other state than Tennessee, nor did it have any corporate officers, directors, offices, or employees in any other state during that period. Nevertheless the corporation contends it is wholly exempt from Tennessee corporate taxation upon the ground that it is nothing more than an “accounting entity” or “incorporated file drawer” and does not…