This analysis includes looking at antecedent legislative enactments for certain purposes.Shepard v. Oklahoma Department of Corrections , 2015 OK 8, ¶ 15, 345 P.3d 377, 382 (workers' compensation statutes); Samson Hydrocarbons Co. v. Oklahoma Tax Commission , 1998 OK 82, ¶ 15, 976 P.2d 532, 537-538 (tax statutes).See , e.g. , Samson Hydrocarbons Co. v. Oklahoma Tax Commission , 1998 OK 82, ¶ 15, 976 P.2d 532, 538 (Antecedent legislative enactments may be considered in the construction of amendatory acts in pari materia so that words and phrases employed in the original or antecedent act will be presumed to be used in the same sense in the amendatory enactment.).

To the contrary, the duty to comply is imposed on Visteon in accordance with § 2884(B). ¶ 34 Visteon argues that tax laws must be strictly construed against the sovereign, citing Samson Hydrocarbons Co. v. Oklahoma Tax Com'n, 1998 OK 82, 976 P.2d 532. While that may be the general rule, where the issue is the court's jurisdiction, the proponent of jurisdiction must be held to strict proof. See, Macsuga v. Moreno, 2003 OK 24, 66 P.3d 409 (Although the Workers' Compensation Act is to be construed liberally in favor of workers, claimant must be held to strict proof that he was an employee in order to be covered by provisions.)

20 O.S. 2001 § 123[ 20-123](A)(9). In Samson Hydrocarbons Co. v. Oklahoma Tax Commission, 1998 OK 82, 976 P.2d 532, we explained: In the construction of statutes it is axiomatic that the statute as amended is to be construed as a consistent whole, in harmony with common sense and reason and that every part should be given effect; that amendments are to be construed together with the original act to which they relate as constituting one law and also together with other statutes on the same subject as part of a coherent system of legislation.

) When construing statutes, we must consider relevant portions together, render every part operative, and give force and effect to each. Samson Hydrocarbons Co. v. Oklahoma Tax Com'n, 1998 OK 82, ¶ 15, 976 P.2d 532, 537–538 ; Bryant v. Com'r of Dept. of Public Safety, 1996 OK 134, ¶ 11, 937 P.2d 496, 500.¶ 8 In his first and second propositions, Plaintiff asserts there is no conflict between the Oklahoma City Municipal Code, § 32–146, the parallel statutory provision of 47 O.S. § 10–103, and the disqualification provision of 47 O.S. § 6–205.2(B)(4), and the trial court misapplied the rules of construction to conclude otherwise.

Therefore, in a direct appeal to this Court from an order by Tax Commission, we will "review the entire record made before an administrative agency acting in its adjudicatory capacity to determine whether the findings and conclusions set forth in the agency order are supported by substantial evidence." Samson Hydrocarbons Co. v. Oklahoma Tax Commission , 1998 OK 82, ¶5, 976 P.2d 532, 535. Tax Commission's order will be affirmed "if the record contains substantial evidence in support of the facts upon which the decision is based and the order is otherwise free of error." Id.

" Id. "[W]e must consider relevant portions together" to "render every part operative." Samson Hydrocarbons Co. v. Oklahoma Tax Com'n, 1998 OK 82, ¶ 7, 976 P.2d 532, 537-538; Comer v. Preferred Risk Mut. Ins. Co., 1999 OK 86, ¶ 19, 991 P.2d 1006, 1015, fn. 35. A. Timely Filing

An adjudicatory order will be affirmed on appeal if the record contains substantial evidence in support of the facts upon which the decision is based and the order is otherwise free of error." Samson Hydrocarbons Company v. Oklahoma Tax Commission, 1998 OK 82, ¶ 5, 976 P.2d 532, 535. "In a protest hearing before the Tax Commission, the protestant bears the burden of proving it is entitled to the relief requested."

In this respect, "we must consider relevant portions together, where possible, to give force and effect to each statute." Samson Hydrocarbons Co. v. Oklahoma Tax Com'n, 1998 OK 82, ¶ 15, 976 P.2d 532, 537-538. (Citation omitted).

TRW/Reda Pump v. Brewington, 1992 OK 31, ¶ 5, 829 P.2d 15, 20; Toxic Waste Impact Group, Inc. v. Leavitt, 1988 OK 20, ¶ 10, 755 P.2d 626, 630. Where two statutes, one specific and one general, deal with the same subject matter, the specific statute controls, with both the general and specific provision given "harmonious" effect. See, e.g., Samson Hydrocarbons Co. v. Oklahoma Tax Com'n, 1998 OK 82, ¶ 15, 976 P.2d 532, 537-538; City of Tulsa v. Smittle, 1985 OK 37, ¶ 12, 702 P.2d 367, 370; Beidleman v. Belford, 1974 OK 72, ¶ 17, 525 P.2d 649, 651; In the Matter of the Guardianship of Campbell, 1966 OK 99, ¶ 13, 450 P.2d 203, 205. Statutory construction presents a question of law, and we review the trial court's determination de novo, without deference to the trial court's conclusion. See, e.g., Duncan v. Oklahoma Dept. of Corrections, 2004 OK 58, ¶ 3, 95 P.3d 1076, 1078.

We employ the presumption "that every provision of our statutes has been intended for some useful purpose and should be given effect." Samson v. Oklahoma Tax Commission, 1998 OK 82, ¶ 7, 976 P.2d 532 (citations omitted). In support of disregarding the language in Section 2871 which indicates the Board was without authority to issue the certificates for 2000 and 2001, County Officials argued two statutes require that an erroneous exemption may be corrected at any time.