Volunteer Val-Pak v. Celauro

OPINION

FONES, Justice.

This is a direct appeal by the Commissioner of Revenue from a judgment of the Chancery Court of Knox County awarding plaintiff, taxpayer, a sales tax refund in the sum of $17,797.02.

Volunteer Val-Pak, a Tennessee partnership with its principal office in Knoxville, carried on a direct mail advertising business from 1976 until 1984. In October of 1984, the taxpayer’s records were audited by representatives of the Commissioner of Revenue for the period 1 January 1981 through 30 September 1984, resulting in an assessment of a sales tax deficiency, interest and penalty.…