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  5. 837 S.W.2d 49 (1992)
 

NASHVILLE GOLF & ATHLETIC CLUB v. HUDDLESTON

837 S.W.2d 49 (1992)

NASHVILLE GOLF & ATHLETIC CLUB, Plaintiff-Appellee, v. Joe B. HUDDLESTON, Commissioner of Revenue, State of Tennessee, Defendant-Appellant.

Supreme Court of Tennessee, at Nashville.

July 20, 1992.

Attorney(s) appearing for the Case

Charles W. Burson, Atty. Gen. & Reporter, Pamela Bingham Broussard, Asst. Atty. Gen., Nashville, for defendant-appellant.

Charles A. Trost, Joseph A. Woodruff, Waller, Lansden, Dortch & Davis, Nashville, for plaintiff-appellee.

OPINION

ANDERSON, Justice.

The first question raised in this sales tax direct appeal by the Commissioner of Revenue is whether "initiation deposits," which are paid by members upon joining the taxpayer's club, are taxable under Tenn.Code Ann. § 67-6-212(a)(1) as sales at retail of "dues or fees to membership sports and recreation clubs," or whether they are nontaxable loans or deposits. If the deposits are taxable sales, a second question to be answered...

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