These items are then integral to the process of producing salable sand. The evidence shows that these items transport, convey, or handle the sand before it reaches its final stage. The burden of establishing an exemption from taxation is on the party claiming the exemption. One who claims a tax exemption must bring himself clearly within the exemption provisions of the statute. Statutory exemption provisions are strictly construed against the party requesting exemption.
All doubts concerning exemption are to be resolved against the exemption and in favor of taxation.
We note that we are faced with a disagreement between two administrative agencies as to the interpretation of a statute. 22 Kan. App. Under no circumstances should the contents be used or cited as authority for setting or sustaining a technical position. 77-415 defines a rule and a regulation. 77-421 define how a rule is promulgated.