(dissenting):
When construing a statute, a court’s function is to ascertain and effectuate legislative intention. In pursuit of that goal a court is not free to disregard the letter of the law when the wording of the statute is clear and free from all ambiguity. However, as a corollary to that rule, when the words of the law are not explicit, or where ambiguity exists, courts must attempt to ascertain the intention of the legislature by the application of certain statutory criteria. See Minn.Stat. § 645.16 (1986). Likewise, courts are authorized to employ certain presumptions in ascertaining that intention. Among those presumptions are: (1) that the legislature did not intend a result that is absurd or unreasonable; (2) that the entire statute is to be effective and certain; and (3) that the legislature intends to favor the public interest as against any private interest. See, e.g., Minn.Stat. § 645.17 (1986). My examination of Act of April 25, 1984, ch. 502, art. 6, § 11, 1984 Minn.Laws 492, 564 (the Sales and Use Tax Refund Amendment), leads me to conclude the statutory wording is neither clear nor certain. Therefore, I believe we must resort to ascertainment of legislative intent by reference to statutory rules of construction and the application of statutory presumptions. When that is done, it appears clear to me that the legislature did not intend an unwarranted windfall rebate in favor of those who had placed orders of capital equipment long before the enactment or effective date *810of the statute and without any reliance upon it — the result which ensues from the tax court’s opinion today affirmed by the majority.1 Therefore, I feel constrained to respectfully dissent.
The Act of April 25, 1984, ch. 502, art. 6, § 7, 1984 Minn.Laws 492, 557, codified as Minn.Stat. § 297A.15, subd. 5 (1986), authorized a two percent sales and use tax rebate on certain purchases of capital equipment. The portion of the act engendering this dispute made the rebate available to “sales made after June 30, 1984, and also * * * to purchases of capital equipment and special tooling made after May 1,1984, but not placed in service until after June 30, 1984.” Act of April 25, 1984, ch. 502, art. 6, § 11, 1984 Minn.Laws. 492, 564. The tax court concluded the language used was precise and unambiguous. In arriving at that conclusion, it relied upon this court’s definition of “sale” in Crown Iron Works Co. v. Comm’r of Taxation, 298 Minn. 213, 214 N.W.2d 462 (1974), as the word is used in Minn.Stat. § 297A.01 (1986). We there held, for the purpose of determining the date on which the obligation to pay a sales tax arose, that by reference to Minn.Stat. § 336.2-401 (the Uniform Commercial Code) a “sale” occurred when the seller completes performance by physical delivery of the goods. Because we had defined “sale” in that context, and because the legislature had not thereafter altered the definition of “sale” as used in the tax statute, the tax court concluded that the same definition was to be read into the statute when construing an exemption, and, therefore, when that is done it concluded no ambiguity existed. The majority of this court, while acknowledging the statutory definition is not exclusive, and while admitting the statute is “somewhat inartfully phrased” proceeds, nonetheless, to the conclusion that the words “sale” and “purchase” as used in the rebate statute should be accorded their “customary and accepted” meanings.
To me the statute is not only “somewhat inartfully phrased,” its wording on its face as well as in context is ambiguous. When it employed the words “sale” and “purchase,” what did the legislature intend? Was its intent that “purchase” was to be construed to be synonymous with our construction of the word sale in Crown Iron Works? I would agree that had the legislature simply provided in the 1984 refund amendment that a sale or purchase consummated after a specified date would entitle the purchaser to a two percent rebate, that our holding in Crown Iron Works might be dispositive. Had the legislature so provided, no significant distinction would exist to justify application of a different definition of “sale” or “purchase” when determining the time a sale of goods to be delivered in the future becomes taxable, than when construing the maturity date giving rise to a refund claim. No ambiguity would exist, and, in my opinion, it would not be inappropriate to incorporate the judicial definition arrived at by reference to the Uniform Commercial Code definition in Crown Iron Works. However, that scenario is not this case. To me, the ambiguity here arises from the legislature’s limitation of the refund on “sales made after June 30, 1984, and also * ' * * to purchases of capital equipment * * * made after May 1, 1984, but not placed in service until after June 30, 1984.” This language raises an uncertainty or ambiguity not present in the tax statute being construed in Crown Iron Works. In construing statutes, we are not permitted to ignore a statutory provision or to define particular statutory words out of the context of the language in which they appear. Minn.Stat. § 645.17(2).2 But, it appears to me, that to *811apply the Croton Iron Works construction of “sale” would in the context of this refund amendment do just that: it would result in not only ignoring the effective date clause, but also render it superfluous. It would be superfluous because “date of delivery” would be controlling, thus making the clause itself redundant. I remain unpersuaded by the majority’s attempt to avoid that conclusion. I find nothing in either the record or the legislative hearings to support the majority’s assertion that the refund amendment was contemplated by the legislation to inure to the benefit of any person who, as Color Ad, had long before enactment of the statute committed to the purchase of capital goods for use in Minnesota. Finally, an attempt to reconcile the presumption in Minn.Stat. § 645.17(4) (the presumption that when the legislature uses a word previously defined by the court it intends the same meaning) with that found in Minn.Stat. § 645.17(2) (the presumption that the entire statute be effective and certain) only results in contributing to the uncertainty and ambiguity of the meaning of the statutory language in the refund amendment.
Having concluded the language of the refund amendment is ambiguous, in order to exercise our overall responsibility to construe statutes to effectuate the intention of the legislature, it is proper to refer to contemporaneous legislative history relative to the occasion and necessity for the statute, the circumstances prompting its enactment, and its objective. See Minn.Stat. § 645.16 (1986); Peterson v. Haule, 304 Minn. 160, 230 N.W.2d 51 (1975).
Reference to the contemporaneous legislative history leaves me with no doubt that the 1984 capital refund program represented one reaction of the legislature to publicly aired contentions in 1983 and 1984 that a “poor business climate” existed in the state, which, some asserted, had contributed, at least in part, to the exodus of some business firms to other states. One real economic disadvantage to businesses located in Minnesota arose from a sales and use tax on capital equipment and certain capital tools which had been imposed at higher rates than were similar taxes in adjoining states. To eradicate this disparity, and as part of its larger program to attempt to stimulate economic development and resulting employment, the legislature sought to provide an incentive to businesses either to locate or to remain in the state.3
In this case both Color-Ad and the tax court acknowledge the incentive purpose underlying the refund amendment. Color-Ad does not, nor could it, claim that the orders placed by it for the capital equipment were motivated in any degree by the incentive program, which, of course, hadn’t even been proposed at the time the orders in question had been placed. It does, however, assert that an allowance to it of the rebate would comport with what it asserts to be a broader legislative intent to encourage investment in new plant and productive equipment. I would reject that assertion for two reasons. First, as we have repeatedly held, exemptions in tax statutes are exceptions and are, therefore, to be strictly construed.4 The refund aménd*812ment, though not purporting to grant complete exemption from taxation of sales and purchase of capital goods, does constitute a limitation on the amount of tax ultimately payable and thus is nothing more, than a restricted form of tax exemption. See, e.g., Ramaley v. City of St. Paul, 226 Minn. 406, 412, 33 N.W.2d 19, 22-23 (1948). Secondly, the contemporaneous history óf the legislation demonstrates that while the legislature meant to narrow the comparative discrepancy between taxes payable by Minnesota producers and those payable by business units in surrounding states, it simultaneously was very much aware of the potential revenue loss that would occur as a result of the rebate and accordingly sought to strictly limit it to its incentive purpose. For example, the House Committee on Taxation considered, but rejected, a proposal to set the rebate at three percent. This proposal was rejected because the additional one percent would not likely contribute to the ends sought to be accomplished sufficient to offset the anticipated loss of revenue to the state. For similar reasons, the committee likewise rejected a proposal which, in effect, would, by way of rebate, grant a complete exemption from sales and use tax on capital equipment. See Hearings on H.F. 2106, House Committee on Taxation, 73rd Minn.Leg., April 9, 1984. Therefore, I contend that neither applicable statutory rules of construction nor contemporary legislative history lend support to Color-Ad’s assertion that the legislature in 1984 harbored any intent that firms in the position of Color-Ad were to be entitled to tax rebates as part of a broader scheme of providing for economic development.
As the majority points out, while the literal wording of Minn.Stat. § 297A.01, subd. 3 (1986) demonstrates that the words “sale” or “purchase” as used in the taxing statute may include the transaction involving a transfer of title, the definition is nonexclusive.5 To hold, as the tax court and the majority does, that in the context of the refund amendment a “sale” or “purchase" is never consummated until delivery of possession of the goods, as the commissioner asserts, would largely frustrate the obvious legislative purpose designed to provide an incentive to Minnesota producers to invest in new capital equipment to be utilized in operating Minnesota plants. Additionally, such a limited construction, it seems to me, would result in the very quantum of revenue loss about which legislators expressed concern when debating the refund amendment in 1984. Those debates, it seems to me, clearly indicate the concerned legislators had no intention of providing a windfall at the expense of the public revenues to those, who like Color-Ad, in no sense can be deemed to have made capital investments in reliance on the incentive program.
When the legislature made the refund available on “purchases of capital equipment * 4 * made after May 1, 1984, but not placed in service until June 30, 1984” it intended something specific by including this effective date provision, and likewise providing for a “gap” period. The tax court construed the effective date provision to apply to equipment and special tooling that required “customization and/or shipment,” but not to capital equipment not in existence at the time Ordered. If I interpret the majority opinion correctly, it reaches essentially the same conclusion. It seems more plausible and reasonable to me that by its structuring of the effective date provision, the legislature was making a limited allowance for other instances where a “gap” period exists between order date and delivery — such as orders for future goods, customized goods, or goods that may take some extended shipment time, while simultaneously limiting anticipated revenue loss by excluding the possibility of windfall claims by those who could not conceivably have relied upon the refund statute in placing orders. Undoubtedly, the desired result could have been accomplished by utilization of more precise language. Nonetheless, I believe such construction corn-*813ports with not only the aims but also the apprehensions voiced by concerned legislators during appropriate tax committee hearings.
Minn.Stat. § 297A.01, subd. 3, does not limit the construction of the word “purchase” to that of the word “sale.” Indeed, in Crown Iron Works we focused only on the definition of the word “sale” as used in the context of a statute imposing a tax— not granting an exception. In that connection, and on that occasion, neither explicitly nor impliedly did we attempt to define the word “purchase” as used in that statute. In statutory interpretation the word “purchase” is not necessarily synonymous with that of the word “sale.” The meaning of a word derives from the context of the text in which it appears. In other contexts the words “purchase” and “sale” appear to have been inconsistently defined. For ex-amplé, in tax law “purchase,” to entitle a taxpayer to a demolition refund, needs to be neither accompanied by payment of consideration nor delivery. See, e.g., First Nat’l Bank & Trust Co. of Chickasha v. United States, 462 F.2d 908, 910 (10th Cir.1972) (though involving a real estate transaction “purchase,” as used in tax statute defined as a binding agreement to pay an agreed price). Likewise, in security law a purchase occurs at a time liability to pay is fixed and actual delivery is unessential. J. W. Burress, Inc. v. JLG Industries, Inc., 491 F.Supp. 15, 18 (W.D.Va.1980). On the other hand “sale” has been defined or construed consistent with the construction we provided in Crown Iron Works with respect to time of tax assessment. See, e.g., Copeland Corp. v. Lindley, 50 Ohio St.2d 33, 361 N.E.2d 1344, 1346 (1977) (specific statutory wording); Community Telecasting Serv. v. Johnson, 220 A.2d 500, 503-04 (Me.1966) (sales specifically defined in tax statute); Aurora Country Club, Inc. v. Dep’t of Revenue, 50 Ill.App.3d 756, 7 Ill. Dec. 944, 946, 365 N.E.2d 229, 331 (1977) (tax statute specifically defined “sale”).
Because the meaning of Minn.Stat. § 297A.15, subd. 5 (1986) appears equivocal and ambiguous; and because the legislative history clearly demonstrates the purpose of the statute was to provide an incentive for acquisition of capital equipment by Minnesota businesses by doing so without unduly jeopardizing state revenues; and because Color-Ad did not rely on the statutory incentive in ordering the capital equipment; and because allowance of the statutory refund in these circumstances would frustrate both concerns the legislature had in mind when enacting the refund program, I would reverse the opinion of the tax court and reinstate the decision of the commissioner.
. The amount of the claimed rebate in the instant case is only $11,362.58. However, the record in the tax court indicates that more than $2 million in rebate claims are pending the outcome of this case.
. See also Int'l Trust Co. v. American Loan & Trust Co., 62 Minn. 501, 503, 65 N.W. 78, 79 (1895), where Mr. Justice Mitchell stated the rule:
It is always an unsafe way of construing a statute or contract to divide it, by a process of etymological dissection, into separate words, and then apply to each, thus separated from its context, some particular definition given by lexicographers, and then reconstruct the *811instrument upon the basis of these definitions. An instrument must always be construed as a whole, and the particular meaning to be attached to any word or phrase is usually to be ascertained from the context, the nature of the subject treated of, and the purpose or intention of the parties who executed the contract, or of the body which enacted or framed the statute or constitution.
. In explaining the purpose of the bill engendering the final statute (H.F. 2016), the chairperson of the house tax committee, who also was one of the bill’s authors, asserted that many states taxed sales on capital equipment at 4 percent and that the purpose of the bill was to make existing Minnesota business firms competitive, as well as to remove a deterrence to other concerns from locating in the state. Hearings on H.F. 2016 before the House Committee on Taxes, 73rd Minn.Leg., April 9, 1984. Similar declarations of purpose were made on the same occasion by other representatives on the tax committee. Eventually the provision was incorporated in the Omnibus Tax Bill S.F. 1969 entitled “Economic Development.”
. See, e.g., Ramaley v. City of St. Paul, 226 Minn. 406, 412, 33 N.W.2d 19, 22-23 (1948); County of Hennepin v. Honeywell, Inc., 297 Minn. 112, 117, 210 N.W.2d 38, 41 (1973); Abex Corp. v. Comm’r of Taxation, 295 Minn. 445, 451-52, 207 N.W.2d 37, 41-42 (1973).
. Minn.Stat. § 297A.01, subd. 3 (1986) reads in the pertinent part: "A ‘sale’ and a ‘purchase’ includes but is not limited to * * * (a) any transfer of title or possession * * * of tangible personal property * * (Emphasis supplied.)