not own the materials at the time of installation, it was not the ultimate consumer of the materials, and thus was exempt from sales tax. In support of its assertions, Vermax notes that it entered into separate contracts for the sale of its products and for the installation of those products. Further, Vermax states that it separately invoiced sale and installation charges. However, the deciding issue in this case is whether Vermax owned the products at the time of installation, not how the purchase and installation contracts were entered into and invoiced. Since Vermax was the party claiming a tax exemption, it had the burden to provide evidence that it did not own the materials at the time of installation. Parson Asphalt Prods., Inc. v. State Tax Comm’n, 617 P.2d 397, 398 (Utah 1980) (<HOLDING>). However, the only evidence Vermax presented
holding act qualifies as exemption statute under exemption 3 holding that when interpreting tax exemption statutes we strictly construe the statute in favor of taxation and against exemption holding a debtors claim for loss of consortium to be entitled to an exemption under the oklahoma exemption statute and collecting other bankruptcy decisions recognizing a debtor spouses loss of consortium as the basis for allowing an exemption under federal and various state exemption statutes holding one who claims tax exemption has burden of showing entitlement to exemption holding that there is no need to consider exemption 6 separately if information was compiled for law enforcement purposes because exemption 7c constitutes broader protection so any information falling under exemption 6 is covered by exemption 7c