I respectfully dissent. I am not persuaded that the legislature intended S.C.Code Ann. § 12-36-920 to include the separate fee charged by intermediaries, such as Travelscape, in the seven percent sales tax “imposed on the gross proceeds derived from the rental or charges for any rooms ... or sleeping accommodations furnished to transients by any hotel----” Accordingly, I would reverse the administrative law court.
Travelscape is an international company which operates primarily as an internet facilitator of hotel reservations. Travelscape does not provide accommodations to the customer. Instead, Travelscape negotiates favorable rates with hotel chains. A Travelscape customer receives the benefit of the *111reduced rate and pays a fee to Travelscape for handling the transaction, all of which is spelled out in the agreement between Travelscape and the customer.
For hotel reservations in South Carolina, a seven percent sales tax is collected on that portion of proceeds derived from the rental of the hotel room. The question before us is whether the legislature intended the statutory seven percent sales tax to reach the separate fee charged by Travelscape for the service it provides. I do not believe the statute unambiguously answers this question. Because it is not clear as to whether Travelscape is subject to § 12-36-920, we must resort to the rules of statutory construction.
S.C.Code Ann. § 12-36-920 (Supp.2009) provides in relevant part:
(A) A sales tax equal to seven percent is imposed on the gross proceeds derived from the rental or charges for any rooms, campground spaces, lodgings, or sleeping accommodations furnished to transients by any hotel, inn, tourist court, tourist camp, motel, campground, residence, or any place in which rooms, lodgings, or sleeping accommodations are furnished to transients for consideration....
(E) The taxes imposed by this section are imposed on every person engaged or continuing within this State in the business of furnishing accommodations to transients for consideration.
I begin with the word “furnish” as it is used in § 12-36-920. Section 12-36-920(A) describes what fees are subject to the tax, while § 12-36-920(E) describes who is subject to the tax. As the majority acknowledges, the word “furnished” as used in subsection (A) connotes physically providing accommodations to customers, which Travelscape does not do. Thus, in order to find Travelscape to be in the business of “furnishing accommodations,” the majority imposes a different meaning of the word “furnish” in subsection (E). Under the majority’s view, “furnish” in subsection (A) is used narrowly and “invokes the connotation of physically providing sleeping accommodations to customers,” while in subsection (E), the phrase “business of furnishing” includes not only those who furnish but *112also those who provide a service to “furnishers” and “transients.”
“A standard principle of statutory construction provides that identical words and phrases within the same statute should normally be given the same meaning.” Powerex Corp. v. Reliant Energy Services, Inc., 551 U.S. 224, 232, 127 S.Ct. 2411, 168 L.Ed.2d 112 (2007). Where the same word is used more than once in a statute, it is presumed to have the same meaning throughout unless a different meaning is necessary to avoid an absurd result. See Busby v. State Farm Mut. Auto. Ins. Co., 280 S.C. 330, 333, 312 S.E.2d 716, 718 (Ct.App.1984). In my opinion, giving the term “furnish” a different meaning in subsection (A) than is given in subsection (E), is in contravention to the rule of statutory construction that the same terms or words in a statute should be given the same meaning.12
I see no reason to deviate from the general rule of statutory construction that the same words within the same statute should be given the same meaning. I believe this is especially so in light of the additional and well-recognized rule of statutory construction, that in the enforcement of tax statutes, the taxpayer should receive the benefit in cases of doubt. South Carolina Nat’l Bank v. South Carolina Tax Comm’n, 297 S.C. 279, 281, 376 S.E.2d 512, 513 (1989). The majority’s construction of the tax statute violates this rule.
Applying the language of § 12-36-920 and utilizing our rules of statutory construction, I am forced to conclude that Travelscape is not subject to the tax. To conclude otherwise would require a clearer expression of legislative intent. I would reverse.
. In my view, the majority’s reliance on Eagle Container Co., LLC v. County of Newberry, 379 S.C. 564, 666 S.E.24 892 (2008) is misplaced. Although we stated in Eagle Container Co. that "words in a statute must be construed in context, and the meaning of particular terms in a statute may be ascertained by reference to words associated with them in the statute,” we were.not concerned with construing the same word within the ordinance that was at issue. Id. at 571, 666 S.E.2d at 895-96 (citations omitted). Rather, the court had to determine whether the phrase "uses permitted” was equivalent to the term of art "permitted use.”