Pan Am World Services, Inc. v. Jackson

OPINION

DROWOTA, Judge.

This direct appeal concerns a tax refund action brought by Plaintiff, Pan Am World Services, Inc., to recover use taxes assessed by Defendant, Donald W. Jackson, the Commissioner of Revenue.1 The determinative issue is whether the fabrication of computer software by Plaintiff’s subcontractor, Computer Scientist Corp., Inc., for the United States Air Force at the Arnold Engineering Development Center in Tulla-homa, Tennessee, is exempt from taxation under T.C.A. § 67-6-102(14)(B). A constitutional issue regarding the jurisdiction of the Claims Commission over revenue…