OPINION
HUMPHREYS, Justice.
This is an appeal by Seagle-Paddock Pools of Memphis, Inc. from a judgment of the Davidson County Chancery Court denying a peremptory writ of mandamus which sought to compel the Commissioner of Revenue to refund taxes it had paid. Seagle-Paddock is a Tennessee corporation with its principal place of business in Memphis. It is engaged in the construction of swimming pools in Tennessee and other states. During the years 1965 and...
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