The interpretation of a statute is a question of law, and therefore, our review is de novo . When interpreting statutes, we must give full effect to the intent of the General Assembly. To determine the legislative intent, we look first to the words used, and these words and phrases must be read in context and accorded their plain and ordinary meaning. When construing tax statutes, there is a presumption that taxation is the rule and exemption from taxation is the exception. The absence of an express exemption indicates a legislative intent to tax.
Corporeal property is that which can be perceived and is tangible.
1 Code Colo. Reg. Further, the statute provides that issuance of a public trustee s deed to the holder of the certificate of purchase confirms the transfer of title. Put another way, title vests in the holder of a certificate of purchase subject to interests senior to the instrument being foreclosed and to the redemption rights of those entitled to redeem. It was this conditional interest that was transferred by Sumitomo to Telluride. The definition does not include a significant number of transactions which can be generally characterized as the transfer of personal property between persons who, or entities which, had an interest, direct or indirect, in the personal property prior to the transfer.