While an administrative interpretation of a statute is not binding on a court, Moto-Pep, Inc. v. McGoldrick, supra, 202 Tenn. at 129, 303 S.W.2d at 330, the 51 percent test is consistent with the express statutory language of T.C.A. §§ 67-6-202 and 67-6-206. Tax statutes are construed in pari materia. See, e.g., Art Pancake's United Rent-All v. Ferguson, 601 S.W.2d 926, 930 (Tenn. App. 1979). We do not disagree with the Plaintiff that the Commissioner could devise another test than the 51 percent test to determine whether a taxpayer is a manufacturer within the meaning of T.C.A. § 67-6-206, but we cannot say that this test bears no rational relation to the statutory requirement; rather, the test is not only consistent with the intent of the statute but it also incorporates the basis on which the Retailers' Sales Tax is computed (i.e., gross sales).

" The plaintiff's argument that it did not owe the property taxes paid on its inventory was confirmed by two decisions of the Court of Appeals in mid-1979, Dixie Rents, Inc. v. City of Memphis, Tenn. App., 594 S.W.2d 397 (1979) and Art Pancake's United Rent-All v. Ferguson, Tenn. App., 601 S.W.2d 926 (1979) in which it was held that companies maintaining inventories of personal property for lease or rental to the public were exempt from personal property taxes on such rental inventories as the gross receipts tax was in lieu of ad valorem personal property taxes. In an effort to recover a refund of the property taxes paid for the taxable year 1978, the plaintiff filed a claim for a refund with the defendant Hackett, County Court Clerk, under the provisions of T.C.A., § 67-1-707(b) (67-2301).

Likewise, we discern no error in the trial court's reference in its final order to interpreting the identical language of the two tax statutes in pari materia. See Art Pancake's United Rent-All v. Ferguson, 601 S.W.2d 926, 930 (Tenn. Ct. App. 1979) ("Tennessee Courts have repeatedly stated that consistent interpretations of related statutes are required in accordance with the in pari materia principle of statutory construction.")

They are complementary taxes and thus should be construed in pari materia. See Art Pancake's United Rent-All v. Ferguson, 601 S.W.2d 926, 930 (Tenn.Ct.App. 1979). Accordingly, precedents construing the sales tax statutes may provide helpful guidance for deciding use tax questions.

On similar facts, we have construed the two predecessors to the statutes at issue to find that the lessor was exempt from property taxes. Art Pancake's United Rent-All v. Ferguson, 601 S.W.2d 926 (Tenn. App. 1979). The issue is resolved by the rationale employed in Eastman Kodak Co., and Cable Systems, Inc. v. Armstrong, 660 S.W.2d 802 (Tenn. App. 1983).

T.C.A. § 67-5801 (Business Tax Act) [now codified as § 67-4-701] provides that "It is the legislative intent that the taxes [based on gross receipts] imposed by this chapter shall be in lieu of any or all ad valorem taxes on the inventories of merchandise held for sale or exchange by persons taxable under this chapter. . . ." We readily agree with our brothers in the Middle Section who wrote, through then Presiding Judge Shriver, in the case of Art Pancake's United Rent-All v. Ferguson, 601 S.W.2d 926 (Tenn. App. 1979) cert. denied (1980), that T.C.A. § 67-616 and § 67-5801 must be construed in pari materia, since there is a direct reference in one statute to the other. In City of Memphis v. American Express Co., 102 Tenn. 336, 52 S.W. 172 (1899), the plaintiff sued the defendant to recover privilege taxes paid by it to the city, alleging that it had paid a similar tax to the state.