Political Subdivision Definition Wyoming
The definition of "political subdivision" were set out in Witzenburger v. State ex rel. Wyo. Community Dev. Authority, 575 P.2d 1100 (Wyo. 1978).
We do not read Witzenburger to require an entity to have all four of the "distinctive badges of a political subdivision," id. at 1113, in order to qualify as a political subdivision.
A computer-aided search of the Wyoming Constitution and statutes reveals that the phrase "political subdivision" is used hundreds of times in dozens of contexts.
Although it is somewhat contrary to the arguments presented by the parties, our conclusion will be founded in simplicity and directness.
In construing a taxing or revenue statute, courts should attempt to ascertain and give effect to the intention of the legislature, and that intention is to be gathered from a consideration of every word in the statute so as to make it harmonious and reasonable in its operation. State v. Union Pacific Railroad Co., 823 P.2d 539, 541 (Wyo. 1992).
As a general rule, tax exemptions are given a strict interpretation against an assertion of a taxpayer and in favor of the taxing power. 3A Sutherland Stat. Const. 66.09, at 42 (5th ed. 1992).
However, the reasons for that rule do not apply in the instance of tax exemptions running to the benefit of the government itself or its agencies. Id. at 43.
In such a case, the practical effect of an exemption is merely to reduce the amount of money that has to be handled by government in the course of its operations. Id. for these reasons, provisions granting exemptions to government agencies may be construed liberally in favor of such agencies. Id.