Saturn Corporation v. Ruth Johnson, Commissioner of Revenue, State of Tennessee

Saturn Corporation appeals the Chancery Court’s entry of summary judgment in the Commissioner’s favor. Saturn filed its action in Chancery Court seeking a refund of a percentage of franchise and excise taxes paid in fiscal year 1999-2000. In this de novo review of the trial court’s judgment, we hold that the exemption claimed does not apply to the taxpayer, that the exemption as applied does not violate the equal protection provisions of state and federal constitutions, and affirm the trial court’s judgment in all respects.