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STATE, DEPT. OF REVENUE v. MOORE

722 S.W.2d 367 (1986)

STATE of Tennessee, DEPARTMENT OF REVENUE, Donald W. Jackson, Commissioner, Petitioner-Appellant, v. James H. MOORE, Whitwell Branch Manager of First Bank of Marion County, and First Bank of Marion County, Respondents-Appellees, and Buck Layne, Jr., Intervenor-Appellee.

Supreme Court of Tennessee, at Nashville.

Rehearing Denied January 5, 1987.

Attorney(s) appearing for the Case

W.J. Michael Cody, Atty. Gen. and Reporter, Daryl J. Brand, Asst. Atty. Gen., Paul E. Terry, Dept. of Revenue, Nashville, for appellant.

Graham Swafford, Jasper, for First Bank.

Ray H. Moseley, Chattanooga, for intervenor.

OPINION

DROWOTA, Justice.

On direct appeal from the Chancery Court of Marion County, this case arises out of a petition to enforce an investigative summons issued by the Department of Revenue, the Petitioner. The summons was issued by Petitioner to the Respondent, First Bank of Marion County, in the course of an investigation of the potential tax liability of one of Respondent's customers. Intervenor, Buck Layne, Jr., is the customer who is the subject of...

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