South Central Bell Telephone Co. v. Celauro

OPINION

HARBISON, Chief Justice.

This case involves the relationship and interplay between portions of the Tennessee excise tax statutes and provisions of the federal Internal Revenue Code. Two separate issues involving interpretations of the Tennessee statutes are presented.

The taxpayer filed for refund for corporate excise taxes allegedly overpaid by reason of disparate accounting for depreciation under the two tax systems. It also claimed that it had not been allowed sufficient credit for depreciation expense under a state statute which compensates for different treatment of tax credits…