Tax exemptions liberally construed for grantee

As a general rule, tax exemptions are strictly construed against the grantee. This is not an absolute rule. The following are cases in which liberal construction is used in favor of the grantee.

[1] If the law granting exemption expressly gives the grantee the benefit of liberal interpretation
[2] If the grantee is a traditional tax exemptee
[3] If the exemption is applied to public property
[4] If the exemption is of clear legislative intent and there is no doubt whatsoever
[5] If the exemption is from special taxes
[6] If the exemption is granted to the government

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