The record before us discloses that Streeterville and the Department had no difficulty agreeing upon the percentage of the parking facility which was used by hospital personnel. Finally, the law is clear that burden of proving the right to an exemption rests upon the party seeking it. The taxpayer seeking exemption must demonstrate by clear and convincing evidence that the exemption applies. 223 Ill. App. Accordingly, we reverse the judgment of the appellate court, affirm the judgment of the circuit court, and remand the cause to the Department for proceedings consistent with this opinion.
Taxation is the rule.
Tax exemption is the exception. Consistent with these principles, statutes exempting property from taxation are to be strictly construed in favor of taxation. If there is any doubt as to applicability of an exemption, it must be resolved in favor of requiring that tax be paid. 289 Ill. App. Ill. Const. 1970, art.