A. COPELAND ENTERPRISES v. COM'R OF REVENUE


703 S.W.2d 624 (1986)

A. COPELAND ENTERPRISES, INC. d/b/a/ Popeye's Famous Fried Chicken, Appellee, v. COMMISSIONER OF REVENUE of the State of Tennessee, Appellant.

Supreme Court of Tennessee, at Jackson.

January 27, 1986.


Attorney(s) appearing for the Case

Charles L. Lewis, Deputy Atty. Gen., Nashville, (W.J. Michael Cody, Atty. Gen. & Reporter, of counsel), for appellant.

Thomas D. Yeaglin, Memphis, for appellee.


OPINION

FONES, Justice.

The issue in this State revenue case is whether plaintiff was a successor in business of Coyote Properties, Inc., within the meaning of T.C.A. § 67-6-513 and as such liable for the unpaid sales taxes that accrued during the time that Coyote Properties operated the business.

The Commissioner determined that Coyote Properties had a delinquent sales tax liability of $20,095.46 and assessed that amount to Copeland Enterprises...

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