OPINION
HUMPHREYS, Justice.
Appellants filed continuation statements, to continue the perfection of security interests in the inventory of their farm implement dealers, in the office of Joe C. Carr, Secretary of State. Against appellants' protests, Thomas D. Benson, Commissioner of Revenue of the State of Tennessee, collected a privilege tax on this recordation under the terms of § 67-4102 T.C.A. Item S(b). Appellants then sued to recover the taxes...
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