Itel Containers International Corp. v. Cardwell

OPINION

ANDERSON, Justice.

This case presents the question whether Tennessee may constitutionally impose a sales tax upon the transfer of possession in Tennessee of domestically-owned cargo containers used exclusively in international commerce. The Chancellor held that the imposition of such a tax is constitutionally permissible. We agree and affirm.

The facts were stipulated at trial as follows:

Itel Containers International Corporation (“Itel”) is a Delaware corporation, with its principal place of business in San Francisco, California. Itel’s principal business is the leasing of cargo…