Coastal Drilling Company, L.L.C. v. Barry J. Dufrene, in His Capacity as Director of St. Mary Parish Sales and Use Tax Department and Ex-Officio Tax Collector for St. Mary Parish

| ¶With all due respect, I dissent from the majority opinion, finding its holding a gross departure by this Court from our *120jurisprudence as well as from the tax exemption law at issue. The First Circuit Court of Appeal opinion authored by Judge Guidry correctly interpreted the tax law at issue, arid there is very little this dissent can add' except to echo the Court of Appeal opinion with more emphasis on the critical points the majority opinion fails to recognize.

Significantly, the majority opinion fails to apply any analysis to its conclusions and makes quantum leaps in reversing the…