NAJO Equipment Leasing, LLC v. Commissioner of Revenue

OPINION

J. Steven Stafford, P.J., W.S.,

delivered the opinion of the Court, in which

Brandon O. Gibson J., and Kenny Armstrong, J., joined.

Taxpayer brought action against the Tennessee Department of Revenue (“Department”) to challenge its assessment of business taxes against taxpayer. Taxpayer asserted it was entitled to an exemption for its leasing trucks and trailers to a public utility. Taxpayer and the Department filed cross-motions for summary judgment. The trial court granted summary judgment in favor of the Department finding that the exemption provision was unambiguous and did not apply…