Worrall v. Kroger Co.

OPINION

COOPER, Chief Justice.

This appeal is from a decree of the Chancery Court of Davidson County that the Kroger Company can offset all personal property taxes paid the Metropolitan Government of Nashville and Davidson County against the gross receipts tax owed by Kroger to Metro under the Business Tax Act.

The Kroger Company filed this action against R. E. Worrall, the County Court Clerk of Davidson County, seeking a refund of gross receipts taxes assessed under the "Business Tax Act” and paid under protest.

The taxpayer, the Kroger Company, is engaged in the business of operating retail…