OPINION
D. MICHAEL SWINEY, J., delivered the opinion of the Court, in which CHARLES D. SUSANO, JR., P.J., and JOHN W. McCLARTY, J., joined.
The State of Tennessee Department of Revenue rendered an assessment against James T. Higdon ("Higdon") for certain business taxes owed. Higdon, challenging the actions taken by the department, sued the State of Tennessee; Commissioner Richard Roberts of the Department of Revenue; and, M. Bernadette Welch of the Department...
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