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  5. 754 S.W.2d 53 (1988)
 

PAN AM WORLD SERVICES, INC. v. JACKSON

754 S.W.2d 53 (1988)

PAN AM WORLD SERVICES, INC., Plaintiff-Appellee-Cross-Appellant, v. Donald W. JACKSON, Commissioner of Revenue, State of Tennessee, Defendant-Appellant-Cross-Appellee.

Supreme Court of Tennessee, at Nashville.

July 18, 1988.

Attorney(s) appearing for the Case

James C. Gooch, Bass, Berry & Sims, Nashville, Thomas M. Hull, Haynes, Hull, Smoot & Reider, P.A., Tullahoma, for plaintiff-appellee-cross-appellant.

W.J. Michael Cody, Atty. Gen. and Reporter, Joe C. Peel, Asst. Atty. Gen., Nashville, for defendant-appellant-cross-appellee.

OPINION

DROWOTA, Judge.

This direct appeal concerns a tax refund action brought by Plaintiff, Pan Am World Services, Inc., to recover use taxes assessed by Defendant, Donald W. Jackson, the Commissioner of Revenue.1 The determinative issue is whether the fabrication of computer software by Plaintiff's subcontractor, Computer Scientist Corp., Inc., for the United States Air Force at the Arnold Engineering Development Center in...

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