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HOLIDAY INNS, INC. v. OLSEN

692 S.W.2d 850 (1985)

HOLIDAY INNS, INC., Plaintiff-Appellee, v. Martha B. OLSEN, Commissioner of Revenue, Defendant-Appellant.

Supreme Court of Tennessee, at Jackson.

June 24, 1985.

Attorney(s) appearing for the Case

Charles L. Lewis, Deputy Atty. Gen., Nashville, for defendant-appellant; W.J. Michael Cody, Atty. Gen. and Reporter, Memphis, of counsel.

Paul J. Hartman, Nashville, Lewis R. Donelson, Charles T. Tuggle, Jr., William H.D. Fones, Jr., Heiskell, Donelson, Bearman, Adams, Williams & Kirsch, Memphis, for plaintiff-appellee.

OPINION

TATUM, Special Justice.

This is an excise tax case concerning state taxation of Holiday Inns, Inc., a multi-state and international business having its commercial domicile in Tennessee. The question presented is whether the interest earned by Holiday Inns from short-term investments of its working capital is non-business income, allocable entirely to Tennessee as the business domicile, or business income which must be apportioned among the several...

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