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  5. 767 S.W.2d 635 (1989)
 

VOLUNTEER VAL-PAK v. CELAURO

767 S.W.2d 635 (1989)

VOLUNTEER VAL-PAK, Plaintiff-Appellee, v. Kathryn Behm CELAURO, Commissioner of Revenue, State of Tennessee, Defendant-Appellant.

Supreme Court of Tennessee, at Knoxville.

March 27, 1989.

Attorney(s) appearing for the Case

W.J. Michael Cody, Attorney Gen. & Reporter, William P. Sizer, Asst. Atty. Gen., Nashville, for defendant-appellant.

Donald F. Paine, Paine, Swiney and Tarwater, Knoxville, for plaintiff-appellee.

OPINION

FONES, Justice.

This is a direct appeal by the Commissioner of Revenue from a judgment of the Chancery Court of Knox County awarding plaintiff, taxpayer, a sales tax refund in the sum of $17,797.02.

Volunteer Val-Pak, a Tennessee partnership with its principal office in Knoxville, carried on a direct mail advertising business from 1976 until 1984. In October of 1984, the taxpayer's records were audited by representatives of the Commissioner...

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