"[I]n construing tax statutes, we are guided by the well-settled principle . . . that a tax exemption is construed to give full effect to the legislative intent of the statute." In re Estate of Martin, 125 N.H. 690, 691 (1984) (quotation omitted). "The starting point in any statutory interpretation case is the language of the statute itself."
Cf. In Re Estate of Martin, 125 N.H. 690, 692, 484 A.2d 1183, 1184 (1984). "Absent a formal legislative history of the statute, we must glean the intent of the legislature from the plain meaning of the language of the statute."
See LSP Assoc., 142 N.H. at 376, 702 A.2d at 799; cf. Hampton Beach Casino, 140 N.H. at 788, 674 A.2d at 981. Although the board specifically rejected a plain reading of RSA 72:23, stating that "such a construction would be . . . inconsistent with the legislature's intent," we must, in the absence of ambiguity and formal legislative history, see In re Estate of Martin, 125 N.H. 690, 691, 484 A.2d 1183, 1184 (1984), derive legislative intent from the statute as written. Petition of Walker, 138 N.H. 471, 474, 641 A.2d 1021, 1025 (1994).
We construe a tax exemption to give full effect to the intent of the regulation. See In re Estate of Martin, 125 N.H. 690, 691, 484 A.2d 1183 (1984), abrogated on different grounds by Pennelli, 148 N.H. at 365.V. Conclusion
[1] A tax exemption statute is construed not with rigorous strictness but "to give full effect to the legislative intent of the statute," and, absent formal legislative history, intent must be gleaned from the plain language of the statute. In re Estate of Martin, 125 N.H. 690, 691, 484 A.2d 1183, 1184 (1984) (quotation omitted). Prior to 1957, the statute authorized a tax exemption to "institutions devoted to educational purposes" provided that "[n]o institution shall be deemed an educational institution for the purpose hereof unless it conducts regular courses of instruction, under a curriculum approved by the state board of education, for at least six months of each calendar year."