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SAFECO v. COM'R OF COMMERCE AND INS.

840 S.W.2d 355 (1992)

SAFECO INSURANCE COMPANY OF AMERICA, General Insurance Company of America, First National Insurance Company of America, Safeco Insurance Company of Illinois, Safeco Life Insurance Company; and Safeco National Life Insurance Company, Plaintiffs-Appellants, v. STATE of Tennessee, COMMISSIONER OF COMMERCE AND INSURANCE, Defendant-Appellee.

Supreme Court of Tennessee, at Knoxville.

September 14, 1992.

Attorney(s) appearing for the Case

Gail Vaughn Ashworth, Nashville, for plaintiffs-appellants.

Charles W. Burson, Atty. Gen. and Reporter, Steven E. Winn, Asst. Atty. Gen., Nashville, for defendant-appellee.

OPINION

REID, Chief Justice.

This case presents an appeal by plaintiff insurance companies from an order of the Tennessee Claims Commission denying the refund of penalties and interest assessed to the plaintiffs by the Commissioner of Commerce and Insurance for the late filing of tax returns and payment of taxes on insurance premiums. The parties agree that the plaintiffs owed and paid the taxes due; the dispute is whether the payments were delinquent and...

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