Abex Corporation v. Commissioner of Taxation

I disagree with the majority’s interpretation and application of Minn. St. 1969, § 272.02(11)(b). The construction placed upon the statute frustrates the legislative purpose of granting property tax relief.

1. Central to the majority’s conclusion that the disputed property in this case constitutes fixtures within the meaning of the tax laws is the rule of statutory construction that statutes which grant exemptions from taxation should be strictly construed against the taxpayer. This is an exception to the normal rule that tax statutes are to be construed in favor of the taxpayer. See, e. g.,…