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...
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