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CONN. BANK & TRUST v. DEPT. OF REVENUE

769 S.W.2d 205 (1989)

The CONNECTICUT BANK AND TRUST COMPANY, N.A., Plaintiff/Appellant, v. TENNESSEE DEPARTMENT OF REVENUE, Defendant/Appellee. FIRST NATIONAL BANK OF BOSTON, Plaintiff/Appellant, v. TENNESSEE DEPARTMENT OF REVENUE, Defendant/Appellee.

Supreme Court of Tennessee, at Nashville.

April 3, 1989.

Attorney(s) appearing for the Case

William M. Barrick, William R. Bruce, Bruce and Barrick, Nashville, for plaintiffs/appellants.

W.J. Michael Cody, Atty. Gen. and Reporter, Daryl J. Brand, Asst. Atty. Gen., Nashville, for defendant/appellee.

OPINION

O'BRIEN, Justice.

The plaintiffs brought action seeking refund of privilege taxes paid under protest pursuant to T.C.A. § 67-4-409. The cases for both plaintiffs were heard in the Davidson County Chancery Court. There does not appear to be any dispute on the material facts alleged. Each of the plaintiffs were involved in a multi-state financial arrangement which involved recording of instruments evidencing indebtedness and imposing liens on...

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