Burden of proof for sales tax exemption failed where buyers could not show sellers were unlicensed dealers.

Exemption from sales tax had to be proved by the taxpayer claiming it, and the petitioners bore the burden of showing that the hides and skins were purchased from unlicensed dealers. The court rejected any presumption that dealers in hides and skins were unlicensed, and accepted the Tribunal's factual finding that the petitioners failed to establish the necessary basis for exemption. On that footing, the claimed exemption was denied and the assessment was sustained.

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Issues: Whether the petitioners were entitled to exemption from sales tax on the ground that the hides and skins were purchased from unlicensed dealers.

Analysis: Exemption from tax had to be established by the person claiming it. The petitioners were required to prove that the sellers from whom they purchased the hides and skins did not hold licences. There was no presumption that every dealer in hides and skins was unlicensed, and the Tribunal's finding that the petitioners failed to prove the necessary facts was upheld.

Conclusion: The petitioners were not entitled to the exemption claimed, and the assessment was sustained.

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