Mississippi Department of Revenue v. Mississippi Power Company

RANDOLPH, Presiding Justice,

for the Court:

¶ 1. This case involves a statutory sales — and use-tax exemption for “pollution control equipment,” an administrative regulation interpreting that exemption, and the application of the statutory exemption and administrative regulation to four low-nitrous-oxide (NOx) burners purchased by Mississippi Power and installed at its Plant Watson and Plant Daniel facilities.

¶ 2. The Mississippi Department of Revenue (MDOR) 1 audited Mississippi Power Company and assessed $251,184.93 in use taxes attributed to Mississippi Power’s purchase and installation of…