Holiday Inns, Inc. v. Olsen

OPINION

TATUM, Special Justice.

This is an excise tax case concerning state taxation of Holiday Inns, Inc., a mul-ti-state and international business having its commercial domicile in Tennessee. The question presented is whether the interest earned by Holiday Inns from short-term investments of its working capital is non-business income, allocable entirely to Tennessee as the business domicile, or business income which must be apportioned among the several states in which plaintiff does business. The Chancellor held that this was business income which must be apportioned and we affirm.

The…