¶20. (dissenting). For the three years preceding January 1997, Schwan's Wisconsin employees numbered between 822 and 907. Its Wisconsin payroll was between $13.4 million and $14.2 million, and its Wisconsin sales were between $66.6 million and $74.2 million. The value of Schwan's Wisconsin property was between $16.9 million and $18.5 million. While these figures might not place Schwan's on the list of the top ten Wisconsin corporations, it is not possible to describe Schwan's presence in Wisconsin as insignificant.
¶ 21. The applicable tax rule is well established by a substantial line of cases. "[T]ax exemption statutes 'are to be strictly construed against the granting of the same, and the one who claims an exemption must point to an express provision granting such exemption by language which clearly specif[ies] the same, and thus bring himself clearly within the terms thereof.' " *259Madison Newspapers, Inc. v. DOR, 228 Wis. 2d 745, 760, 599 N.W.2d 51 (Ct. App. 1999) (quoting La Crosse Queen, Inc. v. DOR, 208 Wis. 2d 439, 446, 561 N.W.2d 686 (1997)); see also Ramrod, Inc. v. DOR, 64 Wis. 2d 499, 504, 219 N.W.2d 604 (1974). "Any doubts or ambiguities as to whether the exemption applies are to be resolved in favor of taxation and against the person claiming the exemption." Madison Newspapers, 228 Wis. 2d at 760.
¶ 22. The majority concludes that the phrase "residents of this state" in Wis. Stat. § 77.54(5) is ambiguous, in that it might mean a corporation's state of incorporation, or it might mean a state where a corporation does significant business. I agree. Where the majority and I differ is the conclusion to be drawn from this observation. The majority concludes that since either of two definitions of "residents of this state" is reasonable, it will accept the definition chosen by the Tax Appeals Commission.
¶ 23. I conclude that courts and commissions alike are bound by published appellate court decisions, including Madison Newspapers, and the cases upon which Madison Newspapers relies. The majority cannot follow the Madison Newspapers rule requiring "language which clearly specif[ies] the [exemption]," 228 Wis. 2d at 760, and at the same time find in favor of Johnson where the exemption is ambiguous. The Tax Appeals Commission, the circuit court, and this court must apply the rule that ambiguities as to whether an exemption applies are resolved in favor of taxation. The majority's determination that the statute granting an exemption for truck bodies manufactured in Wisconsin is ambiguous should lead to only one conclusion: the truck bodies are subject to Wisconsin sales tax. That is *260what the circuit court concluded, and I agree. I therefore respectfully dissent.