OPINION
HARBISON, Justice.
In this case three Virginia banks have filed an action for declaratory and injunctive relief, contending that a 1982 amendment to the Tennessee domestic income tax statutes discriminates against interstate commerce. The statute in question, Tennessee Public Acts 1982, Chapter 652 amended T.C.A. § 67-2601(b) so as to make taxable to Tennessee residents interest income on long-term certificates of deposit
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