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  5. 889 S.W.2d 190 (1994)
 

ASSOCIATED PARTNERSHIP I, INC. v. HUDDLESTON

889 S.W.2d 190 (1994)

ASSOCIATED PARTNERSHIP I, INC., Plaintiff-Appellant, v. Joe B. HUDDLESTON, Commissioner of Revenue, State of Tennessee, Defendant-Appellee.

Supreme Court of Tennessee, at Nashville.

Rehearing Denied December 12, 1994.

Attorney(s) appearing for the Case

James C. Gooch, Michael D. Sontag, Bass, Barry & Sims, Nashville, Kevin R. Conzelmann, John P. Oswald, Lord Day & Lord, Barrett Smith, New York City, for appellant.

Charles W. Burson, Atty. Gen. & Reporter, William E. Young, Asst. Atty. Gen., Nashville, for appellee.

OPINION

ANDERSON, Justice.

In this direct tax appeal, the Chancellor held that the capital gain realized from the sale of a partnership interest by the taxpayer was classified as "business earnings."1 Because we conclude that the capital gain did not arise from a transaction in the regular course of the taxpayer's business, we hold the gain was "nonbusiness earnings." We, therefore, reverse the Chancellor's judgment, which...

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