SCANA Corp. v. South Carolina Department of Revenue

Justice BEATTY:

I respectfully dissent. Because there are clearly divergent interpretations of section 12-14-60(D), I find the effective date language of the carry-forward provision is ambiguous and should be construed against SCANA. Accordingly, I would reverse the decision of the circuit court.

In view of the ambiguity, I believe an application of the rules of statutory construction is necessary to analyze the issue presented in this case. See Kennedy v. S.C. Ret. Sys., 845 S.C. 339, 348, 549 S.E.2d 243, 247 (2001) (“Therefore, since the plain language of the statute lends itself to two…