Crown Enterprises, Inc. v. Woods

OPINION

BROCK, Judge.

This is a suit for the refund of corporate franchise taxes paid under protest for the tax years 1972 and 1973. Plaintiff, Crown Enterprises, Inc., is a Tennessee corporation engaged in the business of acquiring, developing and selling property. One aspect of plaintiff’s business is the construction and development of “Crown Colony,” a planned unit development (PUD) located near Kingsport.

For the years 1972 and 1973 the plaintiff-taxpayer excluded from its franchise tax base $1,406,493.83 (for 1972) and $2,432,- 683.6S (for 1973), 1 amounts representing the value of…