§11-10-25. Taxpayer must show tax exemption applies; presumption.
(a) The burden of proving that a tax exemption applies to any
tax administered by the Tax Commissioner shall be upon the
taxpayer. Tax exemptions administered by the Tax Commissioner
shall be strictly construed against the taxpayer and for the
payment of any applicable tax.
(b) To prevent evasion, it is presumed that a tax exemption
does not apply until the contrary is clearly established by a
preponderance of the evidence.