v. Green, 35 P.3d 14, 22-23 (Alaska 2001); Ayers v. Day & Night Fuel Co., 451 P.2d 579, 581 (Alaska 1969); cf. Dault v. Shaw, 322 P.3d 84, 93-94 (Alaska 2013) (applying the presumption to a prescriptive easement and not- ' ing that “the crucial fact is that the initial use was by permission”). We have not applied this presumption in every case. See Penn, 615 P.2d at 3 (discussing permissive use without applying presumption); Alaska Nat'l Bank v. Linck, 559 P.2d 1049, 1052-54 (Alaska 1977) (not discussing presumption at all). 30 . Vezey, 35 P.3d at 22-23 (quoting Smith v. Krebs, 768 P.2d 124, 126 (Alaska 1989)). 31 . See Glover v. Glover, 92 P.3d 387, 392, 395 (Alaska 2004) (remanding for more factual findings on hostility where occupancy began as a lease); Ayers, 451 P.2d at 581-82 (<HOLDING>). 32 . Peters v. Juneau-Douglas Girl Scout
holding adverse possessor failed to overcome presumption in light of evidence he made a rent payment to fee owners holding that the defendant cannot overcome this presumption of service merely by denying that he did not receive the complaint holding evidence insufficient to overcome presumption of correctness recognizing presumption and finding that it was overcome holding that the presumption that rule 45 does not apply to the federal government can only be overcome by affirmative evidence