Document Type
Article
Publication Date
2-23-2009
Publication Title
State Tax Notes
Publication Title (Abbreviation)
St. Tax Notes
Volume
51
First Page
607
Last Page
609
Abstract
Modern tax statutes serve many purposes beyond simply raising revenue, and the contours of those statutes are shaped by many (and sometimes conflicting) economic, social, and political objectives. Legislatures choose a variety of structural mechanisms – including exemptions, deductions, and credits – to advance those policy goals. Sometimes those features are drafted with less than meticulous precision. Other times, business practices have evolved since enactment of the provisions. In either event, revenue agencies and courts are frequently required to interpret those provisions.
This installment of “Interpretation Matters” concerns one such principle of interpretation: The canon that exemptions, deductions, and credits are construed strictly against the taxpayer. Part I describes the canon. Part II suggests ways by which taxpayers attempt to counter it.
Rights
© 2009 Jeffrey H. Kahn
Faculty Biography
http://www.law.fsu.edu/our-faculty/profiles/johnson
Recommended Citation
Steve R. Johnson,
Interpreting State Tax Exemptions, Deductions, and Credits, 51
St. Tax Notes
607
(2009),
Available at: https://ir.law.fsu.edu/articles/309
Comments
First published in State Tax Notes.