Investors Premium Corp. v. South Carolina Tax Commission

(dissenting) :

Pertinent to the proper disposition of this appeal is the following language from Fuller v. Tax Commission, 128 S. C. 14, 121 S. E. 478:

“(W)here the language relied upon to bring the particular person or subject within the law is ambiguous or is reasonably susceptible of an interpretation that would exclude the person or subject sought to be taxed, the well-established general rule requires that any substantial doubt should be resolved against the government and in favor of the taxpayer (United States v. Merriam [263 U. S. 179], 44 S. Ct. 69, 68 L. Ed. 240). In the application…