City of Bartlett v. Sanders

Summary

The Tennessee Court of Appeals affirmed a judgment finding Franklin Sanders guilty of violating City of Bartlett ordinances requiring a business license and payment of municipal privilege taxes. The court held that evidence that Sanders maintained a business office, advertised as a coin dealer, and exchanged Krugerrands for U.S. currency was sufficient to submit to the jury whether he was engaged in the taxable business of selling coins. The court also rejected Sanders’s arguments concerning legal tender and the absence of a contractual obligation to pay the privilege tax.

Holdings

1. The trial court properly denied Sanders's motion for a directed verdict because material evidence supported a finding that he was engaged in the business of selling coins and therefore was subject to the city's licensing and privilege-tax ordinances.
2. Selling coins and other tangible personal property is a privilege taxable by municipal government, and the evidence was sufficient for the jury to find that Sanders conducted such a business in Bartlett.
3. Sanders's liability for the municipal business tax did not depend on a written contract or other agreement with the City of Bartlett.
4. Foreign gold coins such as Krugerrands are not legal tender for debts under federal law.

Questions Presented

1. Whether the trial court erred by denying Sanders's motion for a directed verdict when the evidence showed that he engaged in the business of selling coins, a business subject to Bartlett's privilege-tax and licensing ordinances.
2. Whether the exchange of Krugerrands for United States currency constituted a taxable sale or business activity under Tennessee law.
3. Whether Sanders could be liable for the municipal business tax without a written contract or agreement with the City of Bartlett.
4. Whether foreign gold coins were legal tender for debts under the federal Constitution and federal law.

Disposition

affirmed