Nashville & Decatur Railroad v. Woods

OPINION

FONES, Justice.

This case involves a construction of the apportionment statutes by which the franchise and excise tax applicable to common carriers was computed for the years 1960-1972.

This litigation is a sequel to Nashville & Decatur R. R. Co. v. Atkins, 489 S.W.2d 837 (Tenn.1973), a declaratory judgment action wherein the railroad sought an adjudication that it was not liable for franchise and excise taxes. Briefly, the gravamen of that action was that the N & D Railroad had leased to the L & N Railroad for a period of nine hundred and ninety-nine years all of its properties,…