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  5. 852 S.W.2d 223 (1993)
 

COMDATA NETWORK v. STATE DEPT. OF REV.

852 S.W.2d 223 (1993)

COMDATA NETWORK, INC., Plaintiff-Appellant, v. STATE of Tennessee DEPARTMENT OF REVENUE and the Commissioner of Revenue, Joe Huddleston, Defendants-Appellees.

Supreme Court of Tennessee, at Nashville.

Rehearing Denied April 26, 1993.

Attorney(s) appearing for the Case

Douglas J. Brown, Paul S. Davidson, Stokes & Bartholomew, Nashville, for plaintiff-appellant.

Charles W. Burson, Atty. Gen. and Reporter, William E. Young, Asst. Atty. Gen., Nashville, for defendants-appellees.

OPINION

REID, Chief Justice.

This case presents an appeal by Comdata Network, Inc. from the judgment of the trial court granting the Commissioner of Revenue's motion to dismiss. The record supports the Chancellor's finding that the Commissioner's refusal to allow the taxpayer a "credit carryover" for the tax years 1982 through 1984 cannot be asserted pursuant to T.C.A. §§ 67-1-1801 to 67-1-1807 (1989).

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