Magellan Pipeline Co. v. South Dakota Department of Revenue & Regulation

[¶25.] SDCL 10-45-12.1 is a lengthy listing of sales tax exemptions. The Legislature used different language in the statute to describe two types of exemptions. In the first, the Legislature exempted specifically described “services” performed by “establishments” referenced in the SIC. Representative examples include “health services,” “educational services,” “social services,” “agricultural services,” “forestry services,” and “trucking and courier services.” See SDCL 10-45-12.1.3 In the second, the Legislature more broadly exempted entire “establishments” or “industries.” *408Representative…