{ "id": 1907715, "name": "Jim C. PLEDGER, Director, Arkansas Department of Finance and Administration v. C.B. FORM COMPANY", "name_abbreviation": "Pledger v. C.B. Form Co.", "decision_date": "1994-02-21", "docket_number": "93-844", "first_page": "22", "last_page": "32", "citations": [ { "type": "official", "cite": "316 Ark. 22" }, { "type": "parallel", "cite": "871 S.W.2d 333" } ], "court": { "name_abbreviation": "Ark.", "id": 8808, "name": "Arkansas Supreme Court" }, "jurisdiction": { "id": 34, "name_long": "Arkansas", "name": "Ark." }, "cites_to": [ { "cite": "200 Ark. 655", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 1453414 ], "weight": 2, "year": 1940, "opinion_index": 0, "case_paths": [ "/ark/200/0655-01" ] }, { "cite": "258 Ark. 813", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 1621118 ], "weight": 2, "year": 1975, "opinion_index": 0, "case_paths": [ "/ark/258/0813-01" ] }, { "cite": "732 S.W.2d 118", "category": "reporters:state_regional", "reporter": "S.W.2d", "weight": 3, "year": 1987, "pin_cites": [ { "page": "120" } ], "opinion_index": 0 }, { "cite": "292 Ark. 515", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 1871124 ], "year": 1987, "opinion_index": 0, "case_paths": [ "/ark/292/0515-01" ] }, { "cite": "307 Ark. 213", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 1902475 ], "weight": 2, "year": 1991, "opinion_index": 0, "case_paths": [ "/ark/307/0213-01" ] }, { "cite": "486 S.W.2d 65", "category": "reporters:state_regional", "reporter": "S.W.2d", "case_ids": [ 1627400, 1627382 ], "year": 1972, "opinion_index": 0, "case_paths": [ "/ark/253/0390-01", "/ark/253/0290-01" ] }, { "cite": "253 Ark. 290", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 1627382 ], "year": 1972, "opinion_index": 0, "case_paths": [ "/ark/253/0290-01" ] }, { "cite": "Ark. Code Ann. \u00a7 26-52-401", "category": "laws:leg_statute", "reporter": "Ark. Code Ann.", "year": 1993, "pin_cites": [ { "page": "(12)(a)" } ], "opinion_index": 0 }, { "cite": "800 S.W.2d 690", "category": "reporters:state_regional", "reporter": "S.W.2d", "case_ids": [ 1880886 ], "year": 1990, "opinion_index": 0, "case_paths": [ "/ark/304/0047-01" ] }, { "cite": "304 Ark. 30", "category": "reporters:state", "reporter": "Ark.", "year": 1990, "opinion_index": 0 }, { "cite": "763 S.W.2d 70", "category": "reporters:state_regional", "reporter": "S.W.2d", "case_ids": [ 1891406, 1891407 ], "weight": 2, "year": 1989, "opinion_index": 0, "case_paths": [ "/ark/297/0394-01", "/ark/297/0477-01" ] }, { "cite": "297 Ark. 394", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 1891406 ], "weight": 2, "year": 1989, "opinion_index": 0, "case_paths": [ "/ark/297/0394-01" ] }, { "cite": "827 S.W.2d 646", "category": "reporters:state_regional", "reporter": "S.W.2d", "case_ids": [ 1906021 ], "weight": 2, "year": 1992, "pin_cites": [ { "page": "648" } ], "opinion_index": 0, "case_paths": [ "/ark/309/0030-01" ] }, { "cite": "309 Ark. 47", "category": "reporters:state", "reporter": "Ark.", "weight": 2, "year": 1992, "pin_cites": [ { "page": "33" } ], "opinion_index": 0 }, { "cite": "Ark. Code Ann. \u00a7 26-52-402", "category": "laws:leg_statute", "reporter": "Ark. Code Ann.", "weight": 6, "year": 1992, "pin_cites": [ { "page": "(c)(2)(B)(i)" }, { "page": "(a)", "parenthetical": "emphasis added" }, { "page": "(c)(2)(B)(i)" }, { "page": "(c)(2)(B)(i)", "parenthetical": "emphasis added" }, { "page": "(a)(l)(B) and (2)(A)" } ], "opinion_index": 0 }, { "cite": "836 P.2d 1051", "category": "reporters:state_regional", "reporter": "P.2d", "case_ids": [ 10375244 ], "year": 1992, "pin_cites": [ { "parenthetical": "goods used in business are \"equipment\" when they have identifiable units and a relatively long period of use." } ], "opinion_index": 1, "case_paths": [ "/p2d/836/1051-01" ] }, { "cite": "452 F.2d 1394", "category": "reporters:federal", "reporter": "F.2d", "case_ids": [ 6077908, 783885 ], "year": 1972, "pin_cites": [ { "parenthetical": "metal plates with a cutting edge used to cut sugar beets into thin slices not entitled to tax exemption applicable to \"machinery used in the manufacture of sugar\"" } ], "opinion_index": 1, "case_paths": [ "/ccpa/59/0056-01", "/f2d/452/1394-01" ] }, { "cite": "487 A.2d 124", "category": "reporters:state_regional", "reporter": "A.2d", "case_ids": [ 7911535 ], "year": 1985, "pin_cites": [ { "parenthetical": "the \"machinery\" tax exemption not applicable to clay models" } ], "opinion_index": 1, "case_paths": [ "/a2d/487/0124-01" ] }, { "cite": "295 Minn. 59", "category": "reporters:state", "reporter": "Minn.", "case_ids": [ 312252 ], "year": 1972, "pin_cites": [ { "parenthetical": "lithographic plates custom made for particular printing jobs, usable for only a limited number of impressions and then scrapped, were not \"machinery\" for the purposes of tax exemption" } ], "opinion_index": 1, "case_paths": [ "/minn/295/0059-01" ] }, { "cite": "203 N.W.2d 344", "category": "reporters:state_regional", "reporter": "N.W.2d", "case_ids": [ 312226, 312252 ], "year": 1972, "pin_cites": [ { "parenthetical": "lithographic plates custom made for particular printing jobs, usable for only a limited number of impressions and then scrapped, were not \"machinery\" for the purposes of tax exemption" } ], "opinion_index": 1, "case_paths": [ "/minn/295/0530-01", "/minn/295/0059-01" ] }, { "cite": "259 Ark. 141", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 1619191 ], "weight": 2, "year": 1976, "opinion_index": 1, "case_paths": [ "/ark/259/0141-01" ] }, { "cite": "292 Ark. 515", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 1871124 ], "weight": 2, "year": 1987, "opinion_index": 1, "case_paths": [ "/ark/292/0515-01" ] }, { "cite": "763 S.W.2d 70", "category": "reporters:state_regional", "reporter": "S.W.2d", "case_ids": [ 1891406, 1891407 ], "year": 1989, "opinion_index": 1, "case_paths": [ "/ark/297/0394-01", "/ark/297/0477-01" ] }, { "cite": "297 Ark. 394", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 1891406 ], "year": 1989, "opinion_index": 1, "case_paths": [ "/ark/297/0394-01" ] }, { "cite": "827 S.W.2d 646", "category": "reporters:state_regional", "reporter": "S.W.2d", "case_ids": [ 1906021 ], "weight": 2, "year": 1992, "opinion_index": 1, "case_paths": [ "/ark/309/0030-01" ] } ], "analysis": { "cardinality": 792, "char_count": 17827, "ocr_confidence": 0.869, "pagerank": { "raw": 3.1589691155999194e-07, "percentile": 0.8631688565626799 }, "sha256": "654c0cd97e4c76da919158720b5132d8d1c968ae1ed977adc1a261f786987add", "simhash": "1:8b8e4497a8bec138", "word_count": 2921 }, "last_updated": "2023-07-14T14:45:44.703271+00:00", "provenance": { "date_added": "2019-08-29", "source": "Harvard", "batch": "2018" }, "casebody": { "judges": [ "Hays and Brown, JJ., dissent.", "Brown, J., joins in this dissent." ], "parties": [ "Jim C. PLEDGER, Director, Arkansas Department of Finance and Administration v. C.B. FORM COMPANY" ], "opinions": [ { "text": "Robert H. Dudley, Justice;\nThis case involves the interpretation and construction of the Arkansas Gross Receipts Act of 1941, as amended.The chancellor ruled that the taxpayer\u2019s manufacture of forms, or molds, is exempt from the gross receipts, or sales, tax. We affirm.\nThe taxpayer, C.B. Form Company, manufactures plaster and cardboard forms for sale to its sole customer, American Fuel Cell and Coated Fabrics Company, or Amfuel. Amfuel utilizes the forms to build fuel cells that fit into a cavity in the wing and fuselage of military and commercial aircraft. In manufacturing the fuel cells, Amfuel applies a precut rubber sheeting or coated fabric to the exterior surface of the form. Two or more plies may be used. This creates an uncured, or green, fuel cell. The green cell and the form inside it are placed in a large autoclave to complete the adhesion process and make one integral unit of the rubber coated fabric. The heat and pressure of the autoclave, in combination with the form within the fuel cell, cause the uncured cell to acquire its permanent physical shape and characteristics. After curing, the cell and its form are submerged in a hot water vat to soften the interior plaster or cardboard form. The form is removed piece by piece through openings in the cell for fuel lines or refueling portals. The cardboard or plaster form is completely destroyed during removal and is hauled to a landfill as unusable waste. The interior of the fuel cell is inspected and packaged for shipment to the customer.\nThe taxpayer thought that its forms were exempt from the sales tax under that part of the machinery and equipment exemption that provides an exemption for molds and dies, and filed a claim under the Arkansas Tax Procedure Act for a sales tax refund of slightly more than $86,000. The Revenue Legal Counsel of the Department of Finance and Administration denied the claim for refund. The taxpayer filed suit in chancery court and alleged that the Department had erroneously denied its claim for the refund. The case was submitted to the chancellor on a stipulation of facts. The chancellor ruled that the forms came within the exemption that provides for \u201cmolds . . . that determine the physical characteristics of the finished product.\u201d See Ark. Code Ann. \u00a7 26-52-402(c)(2)(B)(i) (Repl. 1992).\nOur standard of review of these cases is well settled. The taxpayer must establish an entitlement to an exemption from taxation beyond a reasonable doubt. Pledger v. Baldor Int\u2019l, 309 Ark. 47, 827 S.W.2d 646 (1992). A strong presumption operates in favor of the taxing power. Ragland v. General Tire & Rubber Co., Inc. 297 Ark. 394, 763 S.W.2d 70 (1989). Tax exemptions are strictly construed against the exemption, and we have written that \u201cto doubt is to deny the exemption.\u201d Baldor, 309 Ark. at 33, 827 S.W.2d at 648. We review tax cases de novo. Pledger v. Easco Hand Tools, Inc., 304 Ark. 30, 800 S.W.2d 690 (1990).\nThe chancellor based his ruling on the following sub-parts of the applicable statute, Ark. Code Ann \u00a7 26-52-402:\nThere is specifically exempted from the tax imposed by this act, the following:\n(1) (A) Gross receipts . .. derived from the sale of tangible personal property consisting of machinery and equipment used directly in producing, manufacturing, fabricating . . . articles of commerce at manufacturing . .. plants ... in the State of Arkansas. . . .\n(2) (B) Machinery and equipment \u2018used directly\u2019 in the manufacturing process shall include, but shall not be limited to, the following:\n(i) Molds and dies that determine the physical characteristics of the finished product or its packaging material.\nArk. Code Ann. \u00a7 26-52-402(a) (Repl. 1992) (emphasis added).\nThe Department makes four assignments of error. The first of these is essentially a non-issue. In it, the Department argues that the forms do not qualify for an exemption as items of tangible personal property sold for resale under Ark. Code Ann. \u00a7 26-52-401(12)(a) (Supp. 1993). The chancellor did not rely on this subsection of the statute, and the taxpayer readily concedes the point. Instead, the taxpayer seeks to claim the exemption under the \u201cmold and die\u201d exemption quoted above. We address the point only to make clear the distinction between the two statutes.\nSection 26-52-401 exempts from the collection of sales or use tax, gross proceeds on products that are sold for resale. The purpose of this statute is to prevent double taxation. Hervey v. Southern Wooden Box, 253 Ark. 290, 486 S.W.2d 65 (1972). Subsection (12)(B) allows property sold for use in manufacturing to be classified as having been sold for resale if the property \u201cbecomes a recognizable, integral part of the manufactured . . . product.\u201d Items that are destroyed or disposed of in the manufacturing process do not qualify for this exemption because if they are destroyed there is no possibility of double taxation. See Ragland v. General Tire & Rubber Co., 297 Ark. 394, 763 S.W.2d 70 (1989). The forms manufactured by the taxpayer in this case do not become a \u201crecognizable and integral\u201d part of the finished fuel cell. If the taxpayer were claiming an exemption under this statute, it would be denied.\nA different section, section 26-52-402, provides the exemption for machinery and equipment used directly in the manufacturing process. The purpose of this \u201cmachinery and equipment\u201d statute is \u201cto encourage capital investment in industrial, utility and manufacturing enterprises\u201d for the \u201cindustrial development of the State.\u201d See Act 113 of 1967 (codified at Ark. Code Ann. \u00a7 26-52-402 (Repl. 1992)) (emergency clause). Section 26-52-402(a)(2)(C) provides that the machinery and equipment exemptions are \u201cincentives to encourage the location of new manufacturing plants in Arkansas, the expansion of existing manufacturing plants in Arkansas, and the modernization of existing manufacturing plants in Arkansas through the replacement of old, inefficient, or technologically obsolete machinery and equipment.\u201d The taxpayer contends it is entitled to the exemption under the subsection of this statute that exempts from taxation \u201cmolds and dies that determine the physical characteristics of the finished product.\u201d Ark. Code Ann. \u00a7 26-52-402(c)(2)(B)(i) (Repl. 1992).\nThe heart of the Department\u2019s appeal lies in its second assignment of error. It argues that the taxpayer is not entitled to an exemption under the mold and die exemption, at section 26-52-402(c)(2)(B)(i). There is no dispute about the facts. The parties stipulated that the \u201cwords \u2018form\u2019 and \u2018mold\u2019 are used interchangeably in the industry,\u201d and the Department acknowledges that the forms \u201cdetermine the physical characteristics of the fuel cells.\u201d The Department argues that the chancellor erred as a matter of law in ruling that the forms come within the exemption for \u201cmolds and dies that determine the physical characteristics of the finished product.\u201d\nThe Department contends that, pursuant to our cases, a mold must have continuing utility and be dynamic to qualify as machinery and equipment. It argues that since these molds are destroyed, they have no continuing utility, and are not dynamic and, therefore, do not qualify for the exemption. The argument misses the point that the forms come within the express language of the exemption for \u201cmolds and dies that determine the physical characteristics of the finished product.\u201d\nThe .statute provides an exemption for molds that determine the physical characteristics of the finished product. It does not require that they be permanent. We have often written that legislative intent must be gathered from the plain meaning of the language used in an act. Roy v. Farmers & Merchants Inc. Co., 307 Ark. 213, 819 S.W.2d 2 (1991). The meaning of the words used in mold and die exemption is clear: There is an exemption for molds that determine the physical characteristics of the finished product. In addition, when the sentence in the subsection exempting molds is read in full, it appears that the Department\u2019s argument is contrary to the expressed legislative intent. The full sentence providing the exemption is \u201cMolds and dies that determine the physical characteristics of the finished product or its packaging material\u201d Ark. Code Ann. \u00a7 26-52-402(c)(2)(B)(i) (emphasis added). Packaging material would not ordinarily have continuing utility. There is no expressed legislative intent to construe the statute as proposed by the Department.\nThe Department\u2019s argument that equipment or machinery must have \u201ccontinuing utility\u201d had its genesis in our case of Ragland v. Dumas, 292 Ark. 515, 732 S.W.2d 118 (1987). In that case the trial court ruled that gravel, which was used as a base for a temporary road to an oil extraction project, was exempt under section 26-52-402 as \u201cequipment\u201d used directly in the process of extracting oil. We reversed and held that the term \u201cequipment\u201d did not include gravel used on a temporary road. We noted that the term \u201cequipment\u201d was not defined in the statute, and is \u201can exceedingly elastic term, the meaning of which depends on context.\u201d Id. at 520, 732 S.W.2d at 120. We then looked at definitions of the term and held that gravel did not fit within any of them. One of the reasons for this holding was that the gravel had no continuing utility after the oil-extraction project ended. Id. Unlike the statute applicable to that case, the subsection of the statute applicable to the case at bar specifically defines molds that determine the physical characteristics of the finished product as \u201cmachinery and equipment.\u201d Thus, under the language of the statute, it is not necessary that molds have a \u201ccontinuing utility\u201d to come within the statutory definition of equipment.\nThe Department similarly argues that molds cannot come within the mold and die exception unless they also fall within the definition of \u201cmachinery\u201d that we set out in Heath v. Research-Cottrell, Inc., 258 Ark. 813, 529 S.W.2d 336 (1975). In that case, the taxpayer sought an exemption for a cooling tower as machinery under section 26-52-402. The statute did not define the term \u201cmachinery\u201d and we construed it to mean something dynamic. Contrary to the statute involved in that case, the subsection of the statute applicable to the case at bar defines molds that determine the physical characteristics of the finished product as \u201cmachinery and equipment.\u201d Again, the forms at issue fit within the express language of the statute as \u201cmachinery and equipment.\u201d\nThe Department\u2019s third assignment is valid, but does not change the result of the case. In his letter opinion, the chancellor erroneously referred to section 26-52-402(c)(2)(B)(iv) as additional authority for his ruling in this case. The Director correctly points out that the subsection cited by the chancellor refers to an exemption for the machinery and equipment producing chemical catalysts and solutions, but not to the chemicals and solutions themselves. Thus, the cited subsection does not give an additional reason to support the chancellor\u2019s ruling. Even so, the result of the case is the same since we affirm the ruling on the ground that the taxpayer clearly comes within the mold and die exception as set out above.\nIn its final argument the Department contends that, even if the taxpayer\u2019s forms fit within the definition of \u201cmolds and dies,\u201d they still do not qualify for an exemption because the statute only exempts an initial purchase, or a complete replacement, of a machine or equipment. The Department\u2019s argument is correct in its assertion that only new or replacement machines or equipment are exempt, and that repairs are not exempt. See Ark. Code Ann. \u00a7\u00a7 26-52-402(a)(l)(B) and (2)(A)-(B). Even so, the forms in this case clearly come within the language of the mold and die exception, whether they be classed as initial purchases or replacement molds.\nIn this same argument, the Department contends that the taxpayer is limited to an exemption for the initial mold, and not for replacement molds because Arkansas Gross Receipts Tax Regulation GR-56 requires sellers of molds and dies to collect a tax upon replacement molds and dies that are sold to be used with power units. The director contends that since these molds are not part of a machine they \u201cfail to satisfy an initial requirement for exemption\u201d under the regulation. The argument is without merit for either of two reasons. First, the argument was not raised below, and we will not consider an argument for the first time on appeal. Second, if the Department is seeking to use its power of regulation to impose a requirement that a mold be a part of a power unit in order to be exempt, it has exceeded its authority. An administrative regulation cannot be contrary to a statute. See State v. Burnett, 200 Ark. 655, 140 S.W.2d 673 (1940). The statute provides an exemption for the molds.\nAffirmed.\nHays and Brown, JJ., dissent.", "type": "majority", "author": "Robert H. Dudley, Justice;" }, { "text": "Steele Hays, Justice, dissenting.\nAdmittedly, it is not entirely clear the legislature did not intend the words \u201cmolds and dies\u201d to apply to the forms produced by C.B. Form Company (Company) and used by its sole customer, Amfuel, to produce fuel cells. But neither is it clear that the legislature did so intend and, unfortunately for the Company, that is the stringent test it must surpass to prevail in this litigation. In fact, in order to qualify for the exemption the Company must establish beyond a reasonable doubt that such was the intent of the legislature. Ragland v. General Tire and Rubber Co., 297 Ark. 394, 763 S.W.2d 70 (1989); Heath v. Westark Poultry Processing Corp., 259 Ark. 141, 531 S.W.2d 953 (1976). This case, perhaps more than any other in recent memory, illustrates the maxim applicable to taxation exemption: \u201cto doubt is to deny the exemption.\u201d Pledger v. Baldor International, Inc., 309 Ark. 30, 827 S.W.2d 646 (1992). I respectfully suggest the majority is resolving a doubtful issue against the taxing authority \u2014 the State of Arkansas \u2014 and strictly construing the exemption in favor of the Company, exactly the reverse of settled law.\nIn its baste to judgment the majority equates the words \u2018mold\u2019 and \u2018form\u2019 and effectively decides the case on that basis. The words may be used interchangeably in the industry, but that is not true of the Company, where the word \u2018form\u2019 is consistently used to refer to the disposable device now in dispute and the word \u2018mold\u2019 is used, in contradistinction, to refer to a reusable fiberglass structure utilized by the Company to produce the \u2018form.\u2019 I submit that the reusable device \u2014 the mold \u2014 meets the statutory test but that the nonreusable device \u2014 the form \u2014 does not.\nIf one looks no farther than the words \u201cmolds and dies that determine the physical characteristics of the finished product. . .\u201d the exemption might seem warranted. But to conclude that the form in this case is synonymous with \u2018mold,\u2019 as used in the statute, greatly over simplifies a complex issue.\nThe key words of the statute are \u201cmachinery and equipment\u201d and \u201cmolds and dies.\u201d Certainly the \u2018form\u2019 in this case determines the physical characteristics of the finished product \u2014 the fuel cell. But is that conclusive of the issue being decided? I think not. I submit that a \u2018mold,\u2019 used in conjunction with the word \u2018die,\u2019 when strictly construed against the exemption, contemplates a device which has an ongoing function in the manufacture of a particular product, as opposed to a cardboard structure which, once used, is torn from the product piece by piece and discarded as unusable waste.\nAdmittedly, the statute does not require that molds and dies be permanent. But the two words are linked together in the conjunctive, suggesting a correlation, rather than in the disjunctive, and the word \u2018die\u2019 plainly contemplates an industrial device which is reusable over an extended life. The word is defined as \u201cany of various devices for cutting or forming materials in a press or a stamping or forging machine;\u201d \u201ca hollow device of steel,\u201d \u201ca steel block or plate.\u201d In this context it is far more plausible that by using the words \u201cmolds and dies\u201d (under the broader heading of \u201cmachinery and equipment\u201d) the legislature was referring to devices characteristically similar and having a useful life in the manufacturing process. Indeed, we have recognized that the language used in our statute requires a \u201ccontinuing utility\u201d in order for the exemption to attach. Ragland v. Dumas, 292 Ark. 515, 732 S.W.2d 119 (1987).\nOther states have interpreted the language of similar tax exemption statutes accordingly: See, e.g., Midwestern Press, Inc. v. Commissioner of Taxation, 203 N.W.2d 344, 295 Minn. 59 (1972) (lithographic plates custom made for particular printing jobs, usable for only a limited number of impressions and then scrapped, were not \u201cmachinery\u201d for the purposes of tax exemption); Hasbro Industries, Inc. v. Norbug, R.I., 487 A.2d 124 (1985) (the \u201cmachinery\u201d tax exemption not applicable to clay models); Great Western Sugar Co. v. U.S., 452 F.2d 1394 (1972) (metal plates with a cutting edge used to cut sugar beets into thin slices not entitled to tax exemption applicable to \u201cmachinery used in the manufacture of sugar\u201d); Morgan County Feeders, Inc. v. McCormick, 836 P.2d 1051 (Colo. App. 1992)(goods used in business are \u201cequipment\u201d when they have identifiable units and a relatively long period of use.)\nBeing unable to eliminate all reasonable doubt that the legislature intended the exemption in this instance, I would reverse.\nBrown, J., joins in this dissent.", "type": "dissent", "author": "Steele Hays, Justice, dissenting." } ], "attorneys": [ "Ricky L. Pruett, for appellant.", "Kinard, Crane & Butler, and Woodward & Epley, by; Michael G. Epley, for appellee." ], "corrections": "", "head_matter": "Jim C. PLEDGER, Director, Arkansas Department of Finance and Administration v. C.B. FORM COMPANY\n93-844\n871 S.W.2d 333\nSupreme Court of Arkansas\nOpinion delivered February 21, 1994\nRicky L. Pruett, for appellant.\nKinard, Crane & Butler, and Woodward & Epley, by; Michael G. Epley, for appellee." }, "file_name": "0022-01", "first_page_order": 46, "last_page_order": 56 }