OPINION
O'BRIEN, Justice.
This case originated in the Chancery Court of Cocke County. The State Department of Revenue assessed sales taxes against Carson Creek Vacation Resort in the amount of $32,261 for the period beginning 11 August 1984 through December 1986. The Department based the assessment upon membership fees charged by Carson Creek to its patrons for the use of the resort's campground facilities. Carson Creek paid the assessed tax and interest...
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