Hall Contracting Corp. v. Tidwell

OPINION

DYER, Chief Justice.

This suit was filed by appellee, Hall Contracting Corporation, to recover use taxes paid under protest. The chancellor found for appellee, resulting in this appeal by the appellant, George M. Tidwell, Commissioner of Revenue, of the State of Tennessee.

The City of Memphis, a Tennessee municipal corporation, owns an electrical generating plant known as the Thomas H. Allen Generating Plant, which plant, prior to the events giving rise to this action, was leased to the Tennessee Valley Authority. *698Natural gas is the fuel used by TVA in the operation of this plant and it…