OPINION
REID, Chief Justice.
This appeal presents for review the denial by the Department of Revenue of The Beare Company's application for authorization to purchase water, electricity, and natural gas at the reduced sales tax rates provided by T.C.A. § 67-6-206(b)(1). The chancery court made findings of fact, which substantially conformed to the findings made by the administrative law judge. The court held that, under the statute, the taxpayer is not...
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