Commercial Standard Ins. v. Hixson

,Mr. Justice Cooic

delivered the opinion of the Court.

The complainant is a Texas corporation, qualified to carry on a general insurance business in Tennessee, and, m addition to its general business, exercises the privi lege of guaranteeing titles to real estate in Hamilton County through, the agency of Milligan-Senter Guaranty Title Company, a Tennessee corporation.

The tax imposed upon the business of insuring titles by Article 2, section 1, Item 105', Chapter 108, Public Acts of 1937, was exacted by the State and paid by complainant under protest. This action was commenced to recover from…