WALKER'S, INC. v. FARR

No. W2010-00164-COA-R3-CV.

338 S.W.3d 887 (2010)

WALKER'S, INC. d/b/a Walker's Quality Cleaners v. Reagan FARR, Commissioner of the Department of Revenue, State of Tennessee.

Court of Appeals of Tennessee, Western Section, at Jackson.

September 7, 2010.

Permission to Appeal Denied by Supreme Court February 16, 2011.


Attorney(s) appearing for the Case

Robert E. Cooper, Jr. , Attorney General and Reporter, Michael E. Moore , Solicitor General, and R. Mitchell Porcello , Nashville, Tennessee, for the appellant, Reagan Farr, Commissioner of the Department of Revenue.

Louis F. Allen , Steven H. McCleskey , and Amy Ferguson Dudek , Memphis, Tennessee, and John R. Moss , Jackson, Tennessee, for the appellee, Walker's, Inc.


OPINION

HOLLY M. KIRBY, J, delivered the opinion of the Court, in which ALAN E. HIGHERS, P.J., W.S., and J. STEVEN STAFFORD, J., joined.

This appeal involves the Retailers' Sales Tax Act. The plaintiff taxpayer is a dry-cleaning business. The taxpayer did not pay Tennessee sales tax for the sale of dry-cleaning and laundering services to a formalwear rental business. After an audit, the Tennessee Department of Revenue

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