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  5. 754 S.W.2d 605 (1988)
 

SOUTH CENT. BELL TELEPHONE v. CELAURO

754 S.W.2d 605 (1988)

SOUTH CENTRAL BELL TELEPHONE COMPANY, Plaintiff-Appellee, v. Kathryn B. CELAURO, Commissioner of Revenue for the State of Tennessee, Defendant-Appellant.

Supreme Court of Tennessee, at Nashville.

July 18, 1988.

Attorney(s) appearing for the Case

Raymond Whiteaker, W.W. Berry, Nashville, for plaintiff-appellee.

W.J. Michael Cody, Atty. Gen. and Reporter, Charles L. Lewis, Deputy Atty. Gen., H. Rowan Leathers, III, Asst. Atty. Gen., Nashville, for defendant-appellant.

OPINION

HARBISON, Chief Justice.

This case involves the relationship and interplay between portions of the Tennessee excise tax statutes and provisions of the federal Internal Revenue Code. Two separate issues involving interpretations of the Tennessee statutes are presented.

The taxpayer filed for refund for corporate excise taxes allegedly overpaid by reason of disparate accounting for depreciation under the two tax systems. It also claimed that...

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