dissenting.
[¶ 88] I respectfully dissent. The majority has misstated our law on legislative acquiescence and judicial deference to longstanding administrative agency interpretation of a statute. The majority also ignores Foss v. Gray, 70 N.D. 727, 298 N.W. 1 (1941), in which this Court concluded there was legislative acquiescence to the Tax Commissioner’s longstanding interpretation of “tangible personal property” — even though the interpretation was not contemporaneous with the original adoption of the statute.
[¶ 39] The Tax Commissioner has authority to adopt administrative rules having the force and effect of law. See N.D.C.C. § 57-39.2-19 (“commissioner may prescribe all rules and regulations not inconsistent with the provisions of this chapter, necessary and advisable for its detailed administration and to effectuate the purposes”); N.D.C.C. § 28-32-06 (“Upon becoming effective, rules have the force and effect of law until amended or repealed by the agency, declared invalid by a final court decision, suspended or found to be void by the administrative rules committee, or determined repealed by the office of the legislative council because the authority for adoption of the rules is repealed or transferred to another agency.”). The Tax Commissioner has exercised that authority. The legislature’s interim Administrative Rules Committee reviewed the rule in question to see whether it was properly implemented by the Tax Commissioner or whether it conflicted with legislative intent; the Administrative Rules Committee concluded it did not. See infra ¶¶ 52-60. After that review, the legislature amended and reenacted N.D.C.C. § 57-39.2-02.1 four times, leaving N.D. Admin. Code § 81-04.1-01-28 untouched.
[¶ 40] The coupon books are undeniably tangible — touchable, physical — personal property. The majority does not dispute that taxing such books is clearly within the taxing power of the State. The question becomes, what has the legislature done and what has it intended? The majority does not argue that the answer is clear on the face of the statute, but arrives at its answer by looking to the jurisprudence of states other than North Dakota.
I
[¶ 41] The majority, at ¶¶ 7-8, frames the issue for review as “whether the Commissioner correctly interpreted the phrase ‘[t]angible personal property, consisting of goods, wares, or merchandise’ ” and cites to Northern X-Ray Co., Inc. v. State ex rel. Hanson, 542 N.W.2d 733, 735 (N.D.1996), for the proposition that “whether the Commissioner correctly interpreted a statute is a question of law which is fully reviewable by this Court on appeal.” Northern X-Ray did not involve either legislative acquiescence to an administrative rule or deference to a longstanding administrative agency interpretation of a statute. Although the agency in Northern X-Ray attempted to argue its regulations provided a definition for “contractor,” this Court found the agency’s interpretation was not helpful because its definition of “contractor” contained the same ambiguity *215as the underlying statute. Northern X-Ray, at 738 (“This regulation, however, presents the same problems as the statute: ambiguous use of the term ‘contractor.’ ”). Northern X-Ray focused on the definition of a term neither defined by rule nor subject to a longstanding agency interpretation, a situation entirely different from the one presented here in which an agency’s regulation provides a definition of a statutory term. By relying on Northern X-Ray and framing the issue on appeal as the interpretation of a statute, the majority oversimplifies the analysis appropriate when determining the validity of an administrative rule.
[¶ 42] The majority, at ¶ 10, acknowledges the legislature has reenacted N.D.C.C. § 57-39.2-02.1 since the Tax Commissioner adopted N.D. Admin. Code § 81-04.1-01-28, but it misstates both the doctrine of reenactment and the doctrine of legislative acquiescence as defined by North Dakota case law.
[¶ 43] Two North Dakota cases set forth the general rule of the reenactment doctrine. In Payne v. Bd. of Trustees of the Teachers’ Ins. & Ret. Fund, 76 N.D. 278, 35 N.W.2d 553, 557-58 (1948), this Court discussed the deference that should be given to an agency’s interpretation of a statute when the legislature has subsequently reenacted the statute.
It is not disputed that [the agency’s interpretation] has been the administrative practice since the adoption of the law. During that time the legislature has met in many sessions and made several amendments to the law but none in regard to this procedure. There is at least a strong presumption that the legislature knew and approved the contemporaneous and practical construction placed upon the [statute] by the officers charged with its administration.
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“Executive construction is entitled to additional weight where it has been impliedly indorsed by the legislature, as by the reenactment of the statute or the passage of a similar one, in the same or substantially the same terms, .... ”
This Court cited approvingly to Payne in another case regarding a reenacted statute. See Schmutzler v. Workmen’s Comp. Bureau, 78 N.D. 377, 49 N.W.2d 649 (1951). This Court stated:
Following the codification and the enactment of [the statute], and its reenactment ... the Workmen’s Compensation Bureau continued the interpretation of this Act in accordance with the limitations set out in Chapter 260, S.L.1929. The Bureau treated the statute as unchanged. The practical and contemporaneous construction placed upon the statute by the officers charged with its enforcement may be considered in determining the meaning of the law. See Payne v. Board of Trustees, 76 N.D. 278, 35 N.W.2d 553 and cases cited.
Id. at 652.
[¶ 44] Rather than follow the precedent set forth in Payne and Schmutzler, the majority, at ¶ 11, cites to a treatise on statutory interpretation and cases from foreign jurisdictions for the proposition that “[the reenactment doctrine] does not apply where nothing indicates that the legislature had its attention directed to the administrative interpretation upon reenactment.” Section 49:09 of Statutes and Statutory Construction sets forth the general doctrine of reenactment:
[The reenactment doctrine] is based upon the theory that the legislature is familiar with the contemporaneous interpretation of a statute, especially when made by an administrative body or executive officers charged with the duty of administering or enforcing that statute. *216Therefore it impliedly adopts the interpretation upon reenactment. Legislative adoption is presumed conclusive when repeated reenactments follow a notorious practical interpretation.... The rule is of special importance where administrative rulings and interpretations are under constant observation of the legislature. It does not apply where nothing indicates that the legislature had its attention directed to the administrative interpretation upon reenactment.
2B Norman J. Singer, Statutes and Statutory Construction § 49:09, 108-10 (6th ed.2000 rev.). The majority’s reliance upon the last sentence is misplaced. North Dakota law does not acknowledge this exception. See Schmutzler v. Workmen’s Comp. Bureau, 78 N.D. 377, 49 N.W.2d 649 (1951); Payne v. Bd. of Trustees of the Teachers’ Ins. & Ret. Fund, 76 N.D. 278, 35 N.W.2d 553 (1948).
[¶ 45] In a further attempt to discount the precedent of Payne and Schmutzler, the majority, at ¶ 10, places great emphasis on the “contemporaneous” nature of the interpretations. The majority, at ¶ 10, argues that because here the Tax Commissioner’s interpretation of N.D.C.C. § 57-39.2-02.1 did not take place until “54 years after the Legislature first applied the sales tax to sales of [t]angible personal property, consisting of goods, wares, or merchandise,’ ” the precedent in Payne and Schmutzler does not apply. Again the majority misstates our law on legislative acquiescence.
[¶ 46] “A contemporaneous construction of a statute is ‘given special consideration since it was made at a time when the circumstances leading up to the enactment of the statute were well known.’ ” Johnson v. Wells County Water Resource Board, 410 N.W.2d 525, 529 (N.D.1987) (quoting 2A Sutherland Statutory Construction § 49.08, at 398 (Sands 4th ed.1984 rev.)). Johnson and other cases reciting the contemporaneous nature of an agency’s interpretation do not require that an interpretation be contemporaneous before it-can be given any consideration. See id. Further, in at least two instances, this Court has held the legislature acquiesced in a non-contemporaneous construction of a statute by an administrative agency. See Foss v. Gray, 70 N.D. 727, 298 N.W. 1 (1941); Northern States Power Co. v. Board of R.R. Comm’rs, 71 N.D. 1, 298 N.W. 423 (1941).
[¶ 47] In Voss, this Court was also presented with the issue of whether an agency’s interpretation of what constituted a sale under the phrase “sale ... of tangible personal property” was contrary to legislative intent. Foss v. Gray, 70 N.D. 727, 298 N.W. 1, 2 (1941). The transaction at issue was a sale of photographs by a photographer. Id. The Tax Commissioner determined the sale of photographs “result[ed] in a sale of tangible personal property” and was taxable. Id. at 2-3. The taxpayer argued the photographs were the sale of personal services, “his artistic ability and skill.” Id. at 3. The taxpayer also argued, because the sale of photographs was not originally determined to be a taxable sale, the Tax Commissioner was prohibited from taxing the sale of photographs. Id. at 4. This Court deferred to legislative acquiescence and stated:
Plaintiff also urges that when the Sales Tax Act, supra, was first enacted in 1935, the tax commissioner who was charged with its enforcement, ruled that no tax charge should be made on account of the sale of photographs; that this ruling was in effect in 1937 when the Sales Tax Act was re-enacted; that the legislature is presumed to have known of the ruling and accordingly the act was re-enacted with that ruling in mind. So plaintiff contends it must be *217held that this construction of the 1935 act was adopted by the re-enactment of the act in 1937.
It is true that in construing a statute of doubtful meaning a court will give weight to the practical construction placed thereon by the officers charged with the duty of executing and applying the statute, especially where the construction has been in effect for a considerable time and acquiesced in by those affected by it. And it is likewise true that the legislature is presumed to know the construction of its statutes by the executive departments of the state. And where a statute which has been given a particular practical construction by the officers charged with its application and enforcement is re-enacted, this fact is pertinent in determining the legislative intent, and the presumption is that the legislative intent was that the re-enacted statute should be thus construed. But this is, after all, only a presumption and may be overborne when all the circumstances in connection with the matter are taken into consideration. In the instant case it appears that when the Sales Tax Act was first put into effect in 1935, the Tax Commissioner’s office did rule that no sales tax should be charged and collected by photographers for photographs made and sold. The Sales Tax Act, chapter 276, Session Laws 1935, imposed the tax only for the period “beginning the first day of May, 1935, and ending May 1,1937.” In 1937 this act was re-enacted with but slight changes and the tax was reimposed for the period “beginning the first day of May, 1937, and ending June 30th, 1939.” Immediately after its re-enactment the tax commissioner amended his prior ruling as to the effect of the tax with respect to photographers, and ruled that they should collect a charge in the amount of the tax on photographs made and delivered to their customers for a consideration by them. This ruling has continued in effect since that time. While it was so in effect in 1939, the legislative assembly again re-enacted the Sales Tax Act without change and provided that the tax should be imposed for the period “beginning the first day of July, 1939, and ending June 30th, 1941.” And again in 1941 the tax was reimposed for the period “beginning the first day of July, 1941, and ending June 30, 1943.” We think that under these circumstances it cannot be said that the legislative intention was that no tax should be charged on account of the sale of photographs to their customers by photographers.
Id. at 4-5 (emphasis added). As demonstrated in Voss, the contemporaneous nature of an interpretation is not controlling. In Voss, this Court held that a legislative reenactment followed by a change in agency interpretation, and a subsequent reenactment by the legislature, results in the legislative acquiescence and agreement to the intent embodied in the more recent agency interpretation. Id. at 5.
[¶ 48] Similarly, in Northern States Power Co. v. Board of R.R. Comm’rs, this Court held the legislature had acquiesced in a statutory interpretation by an administrative agency even when the agency had reversed its prior interpretation. The Board of Railroad Commissioners was required to set the fair value of properties used to provide electric, gas, and steam heat services when establishing the rate base for those services. 71 N.D. 1, 298 N.W. 423, 427 (1941). Beginning in 1913, the Board of Railroad Commissioners determined “fair value” using the “prudent investment” or “original cost” method when setting rates. Id. at 427, 430. Then, in 1923, the Board of Railroad Commissioners began to follow federal precedent *218and determine “fair value” using the “value of the property ... as of the time of the inquiry” or “reconstruction value” method of setting rates. Id. at 430. The second interpretation by the Board of Railroad Commissioners was consistently followed after 1923 and “received judicial approval in the case of City of Grand Forks v. Red River Power Co., which was appealed to the District Court.” Id. This Court stated:
Thus for almost twenty years [the statute] has been construed by the Board of Railroad Commissioners as a statutory adoption of the rule of valuation laid down by the Federal Courts commencing with the decision in Smyth v. Ames. Ten Legislative Assemblies have met since the Commission’s decision in re Western Electric Co., and no amendment has been made of the statute. As was said by Judge Nuessle, in State v. Equitable Life Assurance Society, 68 N.D. 641, 653, 282 N.W. 411, 416: “This is pertinent in determining the legislative intent. The ‘Legislature is presumed to know the construction of its statutes by the executive departments of the state.’ ”
Id. at 430 (citations omitted). This Court summarized by stating, “ ‘in construing a statute of doubtful meaning the court will give weight to the long-continued practical construction placed thereon by officers charged with the duty of executing and applying the statute’ to the judicial construction of such statute by an inferior court, and to the legislative acquiescence in both the departmental and judicial construction.” Id. at 430 (citations omitted).
[¶ 49] As Voss and Northern States Power demonstrate, a “non-contemporaneous” interpretation by an administrative agency is entitled to deference and may also be used as evidence of legislative intent.
[¶ 50] More recently, in Effertz v. N.D. Workers Comp. Bureau, 525 N.W.2d 691, 693 (N.D.1994), we reviewed a challenge to the Workers Compensation Bureau’s interpretation of the phrase “weekly benefit.” We concluded the legislature had acquiesced by failing to amend the statute:
The legislature is presumed to know the construction of its statutes by the executive departments of the State and the failure to amend the statute indicates legislative acquiescence in that construction.
Id.; see also Eklund v. Eklund, 538 N.W.2d 182, 188 (N.D.1995) (legislature is presumed to know the construction of its statutes and acquiesces in that construction if it fails to offer any amendments); Capital Electric Coop., Inc. v. Public Service Comm’n, 534 N.W.2d 587, 592 (N.D. 1995) (same).
[¶ 51] Contrary to the majority’s conclusion, the legislature’s chosen action of reenacting N.D.C.C. § 57-39.2-02.1 without amendment is evidence of the legislature’s acquiescence in the construction given the statute by the Tax Commissioner. See, e.g., Effertz, 525 N.W.2d at 693. Even if we were to adopt the interpretation of the reenactment doctrine relied upon by the majority, it would not apply to this case because the legislature’s attention was directed to the amendment made to N.D. Admin. Code § 81-04.1-01-28.
II
[¶ 52] Although the majority, at ¶ 11, states “there is nothing in the legislative history of N.D.C.C. § 57-39.2-02.1 or in the record before this Court to indicate the Legislature considered the 1989 amendments to N.D. Admin. Code § 81-04.1-01-28 during any of the reenactments of N.D.C.C. § 57-39.2-02.1,” the Administrative Rules Committee reviewed the adoption and each amendment of N.D. Admin. *219Code § 81-04.1-01-28. See Minutes of the Administrative Rules Comm. 10-11 (March 29, 1990); Minutes of the Administrative Rules Comm. 8 (July 11, 1989); Minutes of the Administrative Rules Comm. 9 (March 24, 1988); Minutes of the Administrative Rules Comm. 12 (October 14,1986).
[¶ 53] The Administrative Rules Committee is provided for in N.D.C.C. § 54-35-02.5. Section 54-35-02.6, N.D.C.C., sets forth the Committee’s duties and provides, in part:
The administrative rules committee shall review administrative rules adopted under chapter 28-32. The committee shall consider oral and written comments received concerning administrative rules. The committee shall study and review administrative rules and related statutes to determine whether:
1. Administrative agencies are properly implementing legislative purpose and intent.
2. There is dissatisfaction with administrative rules or with statutes relating to administrative rules.
3. There are unclear or ambiguous statutes relating to administrative rules.
The committee may make rule change recommendations to the adopting agency and may make recommendations to the legislative council for the amendment or repeal of statutes relating to administrative rules.
[¶ 54] Section 81-04.1-01-28, N.D. Admin. Code, first became effective October 1, 1986, and it has been amended three times since. See N.D. Admin. Code § 81-04.1-01-28 (effective Oct. 1, 1986; amended effective March 1, 1988; July 1, 1989; March 1, 1990). The language regarding the taxation of coupon books appeared in amendments effective July 1, 1989. Id.
[¶ 55] The July 1, 1989, amendments to N.D. Admin. Code § 81-04.1-01-28 were reviewed at the July 11, 1989, meeting of the Administrative Rules Committee. Minutes of the Administrative Rules Comm. 8 (July 11, 1989). The Committee did not challenge the changes to N.D. Admin. Code § 81-04.1-01-28. Id. The information provided by the Office of the State Tax Commissioner to the Administrative Rules Committee’s July 11, 1989, meeting included the full text of the rule and this description of the subject matter of the changes:
Sales and Use Tax Rules: These rules define activities subject to and exempt from the sales and use tax, and the procedure for calculating and reporting sales and use taxes.
Id. at appendix K.
[¶ 56] The 1991 Report of the North Dakota Legislative Council contains the report from the Administrative Rules Committee’s review of administrative rules changed between October 1988 and October 1990. Report of the N.D. Legis. Council 11-15 (1991). Table A of the report shows the Administrative Rules Committee reviewed 64 amendments, creations, or repeals of rules adopted by the Tax Commissioner during this period. Id. at 15.
[¶ 57] When N.D. Admin. Code § 81-04.1-01-28 was originally enacted, and each time it was amended, the Tax Commissioner or a representative from the Office of the State Tax Commissioner provided information explaining any changes in the rules and answering any questions posed by the Administrative Rules Committee. See Minutes of the Administrative Rules Comm. 10-11 (March 29, 1990); Minutes of the Administrative Rules Comm. 8 (July 11, 1989); Minutes of the Administrative Rules Comm. 9 (March 24, 1988); Minutes of the Administrative *220Rules Comm. 12 (October 14, 1986). The Administrative Rules Committee did not object to the adoption of N.D. Admin. Code § 81-04.1-01-28 or it subsequent amendments. See Minutes of the Administrative Rules Comm. 10-11 (March 29, 1990); Minutes of the Administrative Rules Comm. 8 (July 11, 1989); Minutes of the Administrative Rules Comm. 9 (March 24, 1988); Minutes of the Administrative Rules Comm. 12 (October 14, 1986). The Committee was aware of its ability to object to any rule it deemed “unreasonable, arbitrary, capricious, or beyond the authority” of the agency, because the Legislative Council reports reveal objections made by the Rules Committee during this time. See Report of the N.D. Legis. Council 12-16 (1987); see also Report of the N.D. Legis. Council 11-15 (1991); Report of the N.D. Legis. Council 11-15 (1989).
[¶ 58] In footnote 3, the majority argues, “the fact that the eleven members of the Administrative Rules Committee present at the July 11, 1989, meeting did not object to the 1989 amendments to N.D. Admin. Code § 81-04.1-01-28 is not evidence that the Legislative Assembly as a whole approved of the amendments.” The majority apparently concludes review by the Administrative Rules Committee can never be evidence of legislative intent, even though the Committee is charged with determining “whether administrative agencies are properly implementing legislative purpose and intent” and the conclusions of the Committee are presented to the Legislative Council and the entire Legislative Assembly through the Legislative Council’s Report to the Legislature. See N.D.C.C. § 54-35-02.6; see, e.g., Report of the N.D. Legis. Council, 11-15 (1991). The majority’s conclusion effectively destroys the main objective of the Committee and strains the phrase “brought to the legislature’s attention” to its outermost limits. If the review by a legislative committee created for the purpose of reviewing administrative agency action for consistency with legislative intent is not sufficient evidence to show the legislature’s attention was directed to the administrative action, what is?
[¶ 59] Accordingly, the majority’s statement, at ¶ 11, that “there is nothing ... to indicate the Legislature considered the 1989 amendments to N.D. Admin. Code § 81-04.1-01-28 during any of the reenactments” is incorrect because it ignores the Administrative Rules Committee’s review of N.D. Admin. Code § 81-04.1-01-28. More important, the majority’s conclusion ignores North Dakota law prior to the creation of the Administrative Rules Committee in 1979. See N.D.C.C. § 54-35-02.6. In Payne, Schmutzler, Northern States Power, and Foss, this Court concluded the legislature had acquiesced in an agency’s interpretation of a statute without any evidence the legislature’s attention had been directed to the agency’s interpretation. Here, we have not only the legislature’s four-time reenactment of N.D.C.C. § 57-39.2-02.1 since the adoption of N.D. Admin. Code § 81-04.1-01-28, but we also have the Administrative Rules Committee’s review of the adoption of N.D. Admin. Code § 81-04.1-01-28.
[¶ 60] In reaching its conclusion that the legislature’s attention was not specifically directed to the Tax Commissioner’s interpretation of N.D.C.C. § 57-39.2-02.1, the majority has created a standard for legislative acquiescence in an administrative agency’s interpretation that differs from the standard for legislative acquiescence in a judicial interpretation. In numerous decisions, this Court has concluded the legislature acquiesced in a judicial interpretation of a statute by failing to amend the statute, or by using the same or similar language, or by reenacting the *221statute, without mention of whether the legislature’s attention was directed to the judicial interpretation. See, e.g., Western Nat’l Mut. Ins. Co. v. University of North Dakota, 2002 ND 63, 643 N.W.2d 4; Clarys v. Ford Motor Co., 1999 ND 72, 592 N.W.2d 573; State v. Palmer, 1999 ND 40, 592 N.W.2d 923; State v. Martineau, 1999 ND 41, 592 N.W.2d 923; Lawrence v. Delkamp, 1998 ND 178, 584 N.W.2d 515; Hassan v. Brooks, 1997 ND 150, 566 N.W.2d 822; Hovland v. City of Grand Forks, 1997 ND 95, 563 N.W.2d 384; Krehlik v. Moore, 542 N.W.2d 443 (N.D.1996); City of Bismarck v. Uhden, 513 N.W.2d 373 (N.D.1994); In re B.G., 477 N.W.2d 819 (N.D.1991); Midwest Property Recovery, Inc. v. Job Serv. of N.D., 475 N.W.2d 918 (N.D.1991); Wiederholt v. Dir., N.D. Dep’t of Transp., 462 N.W.2d 445 (N.D.1990); State v. Gefroh, 458 N.W.2d 479 (N.D.1990); Erdle v. Dorgan, 300 N.W.2d 834 (N.D.1980); Skinner v. American State Bank, 189 N.W.2d 665 (N.D.1971); Lembke v. Unke, 171 N.W.2d 837 (N.D.1969); Blair v. City of Fargo, 171 N.W.2d 236 (N.D.1969); Portland Credit Union v. Hauge, 169 N.W.2d 106 (N.D.1969); Public Serv. Comm’n v. City of Williston, 160 N.W.2d 534 (N.D.1968); Kline v. Landeis, 147 N.W.2d 897 (N.D.1966); Lapland v. Stearns, 79 N.D. 62, 54 N.W.2d 748 (1952); McIntyre v. State Bd. of Higher Educ., 71 N.D. 630, 3 N.W.2d 463 (1942); Village of Marion v. C.A. Finch Lumber Co., 52 N.D. 32, 201 N.W. 837 (1924); State v. Poindexter, 48 N.D. 135, 183 N.W. 852 (1921); State ex rel. Linde v. Robinson, 35 N.D. 417, 160 N.W. 514 (1916); State ex rel. Linde v. Packard, 35 N.D. 298, 160 N.W. 150 (1916); State v. Stockwell, 23 N.D. 70, 134 N.W. 767 (1911); Minneapolis & N. Elevator Co. v. Traill County, 9 N.D. 213, 82 N.W. 727 (1900).
Ill
[¶ 61] The omissions and misstatements by the majority lead to a conclusion contrary to North Dakota law. Under North Dakota law, the legislature’s reenactment of N.D.C.C. § 57-39.2-02.1 after the adoption of N.D. Admin. Code § 81-04.1-01-28 must be regarded as an approval of the interpretation of the Tax Commissioner. See Payne v. Bd. of Trustees of the Teachers’ Ins. & Ret. Fund, 76 N.D. 278, 35 N.W.2d 553, 557-58 (1948); Northern States Power Co. v. Board of R.R. Comm’rs, 71 N.D. 1, 298 N.W. 423, 430-31 (1941); Voss v. Gray, 70 N.D. 727, 298 N.W. 1, 4-5 (1941). The legislature, through the Administrative Rules Committee, was aware of and did not object to the Tax Commissioner’s adoption of N.D. Admin. Code § 81-04.1-01-28. The legislature’s failure to amend N.D.C.C. § 57-39.2-02.1 or object to N.D. Admin. Code § 81-04.1-01-28 demonstrates its acquiescence in the Tax Commissioner’s interpretation that coupon books are taxable under N.D.C.C. § 57-32.9-02.1. See Effertz v. N.D. Workers Comp. Bureau, 525 N.W.2d 691, 693 (N.D.1994); Payne v. Bd. of Trustees of the Teachers’ Ins. & Ret. Fund, 76 N.D. 278, 35 N.W.2d 553, 557-58 (1948); Northern States Power Co. v. Board of R.R. Comm’rs, 71 N.D. 1, 298 N.W. 423, 430-31 (1941); Voss v. Gray, 70 N.D. 727, 298 N.W. 1, 4-5 (1941).
[¶ 62] I would affirm the order of the North Dakota State Tax Commissioner holding American West liable for $20,883.51 in sales tax.
[¶ 63] Dale Y. Sandstrom