Columbia Athletic Club v. Director of Revenue

Because the principal opinion is contrary to the plain meaning and settled interpretation of the sales tax law, I dissent. The principal opinion’s novel conclusions do not withstand analysis under the touchstone for statutory construction in this state:

The primary rule of construction of statutes is to ascertain the lawmakers’ intent, from the words used if possible; and to put upon the language of the Legislature, honestly and faithfully, its plain and rational meaning and to promote its object, and the manifest purpose of the statute, considered historically, is properly given consideration.