11 GCA § 26117: Tax Exemption.

If any person desires to claim exemption from any tax levied under this Chapter by virtue of a specific exemption allowed herein, he may be required to furnish the Tax Commissioner a statement under oath setting forth:

(a) The character of the business;

(b) The provision under which such exemption is claimed;

(c) Such additional information as the Tax Commissioner may require or as may be prescribed under the rules and regulations formulated and put into effect under authority of this Chapter;

(d) Upon presentation of the foregoing information, or as much of it as may be required, the Tax Commissioner shall determine whether the activity is taxable or exempt from tax;

(e) The decision of the Tax Commissioner regarding the taxability of any person or business shall be binding, except:

(1) When reversed on appeal to the Tax Appeal Board under the same procedure provided for appeal of tax assessments in this Chapter, or;

(2) When reversed by a court of competent jurisdiction.