South Carolina - Special license tax statute is "ambiguous" and must be construed in the taxpayer's favor

August 2012


The South Carolina Supreme Court found that the state's special license tax was ambiguous because it did not provide a definition of a "telephone company," which is one of the specified entities subject to the tax. Because of the statutory ambiguity, application of the statute was resolved in favor of the cellular service provider taxpayers who were determined not to be telephone companies subject to the heightened special license tax.

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