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COMBUSTION ENGINEERING, INC. v. JACKSON

705 S.W.2d 655 (1986)

COMBUSTION ENGINEERING, INC., Plaintiff/Appellee, v. Donald W. JACKSON, Commissioner of Revenue for the State of Tennessee, Defendant/Appellant.

Supreme Court of Tennessee, at Knoxville.

February 24, 1986.

Attorney(s) appearing for the Case

Michael W. Catalano, Asst. Atty. Gen. (W.J. Michael Cody, Atty. Gen. and Reporter, of counsel), for defendant/appellant.

Carl E. Hartley, C. George Caudle, Chattanooga, for plaintiff/appellee.

OPINION

HARBISON, Justice.

Although there were other issues involved in the trial court, the single issue presented on appeal of this case is the proper rate of interest payable upon a deficiency assessment of excise taxes. Particularly involved is the interpretation of T.C.A. § 67-1-801(a)(2).

The facts of the case were stipulated. The Chancellor held that appellee was liable for additional corporate excise taxes for the years 1971, 1972 and...

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