Court of Civil Appeals of Alabama December 2, 2016, 2150547 (Alabama Department of Revenue v. U.S. Xpress Leasing, Inc.)

DONALDSON, Judge.

The Alabama Department of Revenue (“the Department”) appeals from a summary judgment of the Montgomery Circuit Court (“the trial court”) holding that U.S. Xpress Leasing, Inc. (“USXL”), a Tennessee corporation, is subject to Alabama’s lease tax under § 40-12-222(a), Ala. Code 1975, and, therefore, is.