342 N.C. 374, 380, 464 S.E.2d 268, 271 (1995)). “[S]uch construction is ‘strongly persuasive’ and . . . entitled to ‘due consideration.’ ” See id., 349 N.C. at 302, 507 S.E.2d at 293 (quoting Shealy v. Associated Transp., Inc., 252 N.C. 738, 742, 114 S.E.2d 702, 705 (1960)). Indeed, under operation of N.C. Gen. Stat. § 105-264 (2003), the Secretary’s interpretation of a statute he administers is “prima facie correct.” The taxpayers assert N.C. Admin. Code tit. 17, r. 5C.0102(a) “is of no consequence” because amendments to the income tax statute occurring in 2001 (the “2001 amendments”) indicates “that the agency’s rule [improperly] expanded the income tax statute” instead of interpreting it. See Duke Power Co. v. Clayton, Comr. of Revenue, 274 N.C. 505, 511, 164 S.E.2d 289, 294 (1968) (<HOLDING>). The taxpayers argue the only possible purpose
holding that we review a district courts interpretation of a statute de novo holding that an intervening change in statutory interpretation did not amount to a change in controlling law under the mandate rule where plaintiffs attempted on remand to rely on a different but related statute which could have been but was not previously raised and the interpretation of which had not changed holding an administrative interpretation cannot change the meaning of a statute or control the courts interpretation of it holding erisa plan interpretation is simply one of contract interpretation holding that bias interpretation of immigration law is entitled to deference except where the interpretation is clearly contrary to the plain and sensible meaning of the statute