Baptist Medical Centers v. State, Department of Revenue

BRADLEY, Presiding Judge.

These appeals arise out of the consolidation of two taxpayer refund requests in which the Department of Revenue (the Department) interpreted a new tax exemption statute.

Taxpayers, the Baptist Medical Centers (Baptist) and Mobile Infirmary Association *46(Mobile), requested from the Department refunds from the two hospitals’ payments of sales taxes on drug purchases. Both requests were made pursuant to 1981 Ala. Acts, No. 81-663, which has been codified at section 40-23-4.1, Code 1975. That stab ute, hereinafter referred to as the Exemption Statute, provides:

“(a) The term…