Federated Stores Realty, Inc. v. Huddleston

*207OPINION

REID, Chief Justice.

This case presents an appeal by Federated Stores Realty, Inc. (Federated) from the judgment of the Chancery Court of Davidson County denying Federated’s request for refund of corporate franchise and excise taxes for its four fiscal years ending January 31, 1984 through 1987, the assessment period.

I

Federated is a Delaware corporation with its principal place of business in Cincinnati, Ohio. During the assessment period and at all times relevant to the issues in this case, it was engaged in the business of developing, leasing, and managing real estate in various parts…