Lanigan Storage & Van Company, Inc. v. United States

O’SULLIVAN, Circuit Judge.

We review a decision of the United States District Court for the Western District of Tennessee, upholding the claim of appellee taxpayer, Lanigan Storage & Van Company, Inc., for refund of taxes. The cause was tried to the District Judge, Honorable Bailey Brown, who filed Findings of Fact and Conclusions of Law.

Appellee is a small trucking concern, operating out of Memphis, Tennessee, and engaged in long distance hauling of household furniture. It leases its several tractor-trailer vehicles to Allied Van Lines, Inc., and operates under Allied’s interstate authority…