Hart County Board of Tax Assessors v. Dunlop Tire & Rubber Corp.

It is a well established rule in this state that if a statute levying a tax is of doubtful meaning it is to be construed in favor of the taxpayer and against the taxing authority. Cherokee Brick &c. Co. v. Redwine, 209 Ga. 691, 692 (75 SE2d 550) (1953) (citing numerous cases). However, tax exemptions of doubtful meaning are to be construed in favor of the taxing authority and against the taxpayer. Cherokee Brick &c. Co. v. Redwine, supra, 209 Ga. at 693; Chilivis v. Dixon, 234 Ga. 703, 704 (217 SE2d 283) (1975).

Applying these well established rules to the case at bar, it is clear that it is…