Interpreting State Tax Exemptions, Deductions, and Credits

Posted: 3 Jun 2009 Last revised: 6 Aug 2009

See all articles by Steve R. Johnson

Steve R. Johnson

Florida State University - College of Law

Multiple version iconThere are 2 versions of this paper

Date Written: Feb. 24, 2009

Abstract

Modern tax statutes serve many purposes beyond simply raising revenue, and the contours of such statutes are shaped by numerous (and sometimes conflicting) economic, social, and political objectives. Legislatures choose a variety of structural mechanisms to advance these policy goals, including exemptions, deductions, and credits. Sometimes these 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 these provisions.

This installment of “Interpretation Matters” concerns one principle of such 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.

Keywords: tax statutes interpretation

Suggested Citation

Johnson, Steve R., Interpreting State Tax Exemptions, Deductions, and Credits (Feb. 24, 2009). State Tax Notes, Vol. 51, p. 607, 2009, Available at SSRN: https://ssrn.com/abstract=1413248

Steve R. Johnson (Contact Author)

Florida State University - College of Law ( email )

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