Jewel Companies v. Porterfield

At the outset, we should note that ap-pellee has contended that appellant failed to sustain the burden of proof of exempt use before the Board of Tax Appeals.

*99Appellee argues, and the record shows, that appellant’s only witness to testify before the board had no first hand knowledge of the use of this particular truck. However, the record also shows that the witness testified that all trucks of this type owned by appellant are used exclusively in the operation of its Home Shopping Service in the manner described by the witness.

The Board of Tax Appeals might have chosen to base its decision…