Cummins Engine Co. v. Thomas

Littlejohn, Justice.

This action was brought by Cummins Engine Company, Inc. (Cummins) for the recovery of property taxes paid un*524der protest to the Treasurer of Charleston County (Treasurer) with respect to Cummins’ diesel engine assembly plant.

In its complaint, Cummins alleged it was entitled to recover at least some part of its tax payment on two alternative grounds. The facts on which Cummins based its claim are as follows:

In 1967 Avco Corporation, whose major business at the time was the reconditioning of military helicopter engines, purchased land and constructed manufacturing facilities…