OPINION
FONES, Chief Justice.
The issue in this direct appeal by taxpayer ARB Enterprises d/b/a Sparkle Wash of Chattanooga, is whether the revenue rule promulgated by the commissioner is consistent with the statute and imposes a sales tax upon charges made by taxpayer for cleaning trucks, motor vehicles and other tangible personal property.
Taxpayer is a franchise cleaning operation that utilizes van mounted, mobile pressure washing units. The vans...
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