OPINION
BROCK, Justice.
A.
The plaintiff, Howard Cotton Company, paid under protest for the taxable years 1975 through 1979 the Tennessee Excise Tax on corporate net earnings as assessed by the Commissioner of Revenue under T.C.A., § 67-2701, et seq. (now, T.C.A., § 67-4-801, et seq.). For the years in question the plaintiff paid the tax on 36% of its net earnings, conceiving that it was, under the Tennessee apportionment...
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