General Oils Company, Division of Ashland Oil, Inc., v. Claude Ramsey, Assessor of Property for Hamilton County, Tennessee and TN State Board of Equalization

General Oils Company ("plaintiff") filed suit in the Chancery Court of Davidson County against the Assessor of Property for Hamilton County ("Hamilton County Assessor") and the Tennessee State Board of Equalization ("Board of Equalization") seeking judicial review of the decision by the Assessment Appeals Commission ("AAC") of the Board of Equalization that for tax assessment purposes plaintiff's petroleum storage tanks located in Hamilton County were real property. The chancellor reversed the AAC, holding that the tanks were personal property. On appeal Hamilton County Assessor and Board of Equalization present one issue 1On appeal the Board of Equalization only challenges the lower court's action to the effect that tanks are automatically considered tangible personal property under T.C.A. § 67-5-903(f) for property tax purposes. Because the broader issue raised by Hamilton County Assessor in essence encompasses this secondary issue, we approach this case from the standpoint of Hamilton County Assessor. 2 for our consideration: Whether the trial court erred in holding that the storage tanks should be classified as personal property for tax assessment purposes.1 For the reasons hereinafter stated, we find no error and affirm.