Allenberg Exports, Inc. v. Woods

OPINION

COOPER, Justice.

This action was brought by appellant to recover franchise and excise taxes for fiscal years ending January 31,1973, and January 31,1974, which had been paid under protest. The issue presented is whether or not appellant is entitled to use a statutory apportionment formula for its excise and franchise taxes on the ground that it is doing business “in Tennessee and elsewhere” as provided in T.C.A. §§ 67-2706 and 67-2912.1 The chancellor found that appellant “failed to meet its burden of proving substantial contacts with another state justifying apportionment,” and…