Jersey Miniere Zinc Co. v. Jackson

OPINION

DROWOTA, Chief Justice.

I

In these consolidated cases, Plaintiffs seek refunds for sales taxes paid under protest for the tax years 1981-83. The taxpayers contend that they are entitled to the exemptions for industrial materials *929used and consumed directly in the manufacturing process, T.C.A. § 67-6-102(13)(E), and to the reduced sales and use tax for industrial machinery in effect in the tax years in question, T.C.A. § 67-6-206. After a 1984 audit, Commissioner assessed taxpayers the full rate for sales and use tax. The taxpayers paid the taxes under protest and brought suit. All parties…