Standard Advertising Agency, Inc. v. Jackson

OPINION

HARBISON, Justice.

The taxpayer appeals from the dismissal of its suit for the refund of sales taxes, penalties and interest. After review of the issues presented and the entire record, we affirm the decision of the Chancellor.

The facts were stipulated. The appellant corporation was formed in 1977 as a wholly-owned subsidiary of Service Merchandise Company, Inc., a large retail and mail order mercantile establishment. Service Merchandise formed several other wholly-owned subsidiaries through which part of its merchandising operations were conducted.

Appellant was formed as an advertising…