Constitutional and statutory provisions for exemptions must be strictly construed against the one claiming the exemption, with all doubts being resolved against the exemption. Nevertheless, strict construction does not mean unreasonable construction. The party who seeks exemption bears the burden of showing that it comes within the specific provisions of the statute providing for the exemption. 21 Kan. App. When interpreting a statute, a court must give effect to the intention of the legislature as expressed in the plain and unambiguous language used by the legislature.
Ordinary words are to be given their ordinary meanings.
Statutes should not be read to add what is not found in the language or to delete what is, as a matter of ordinary English, contained in the language. 21 Kan. App. The decision to consider the traditional category for property is supported by considering the implications of applying a use test. Because a backhoe is typically used for construction, its main use is for income generation. If a taxpayer were able to exempt a backhoe from taxation as yard or garden equipment, the County would have to establish that the backhoe was not used as income-producing property.