We granted certiorari to review a court of appeals decision reversing the Utah State Tax Commission's ("the Commission") assessment of sales tax on Newspaper Agency Corporation's ("NAC") purchase and reconfiguration of printing presses. See Newspaper Agency Corp. v. Utah State Tax Comm'n, 892 P.2d 17 (Ct.App.), cert. granted, 910 P.2d 425 (Utah 1995). In Newspaper Agency Corp., the court of appeals first invalidated the Commission's rule defining the phrase "new or expanding operations" found in section 59-12-104(16) of the Utah Code. Id. at 21-22; see Utah Admin. Code R865-19-85S(A)(3) (1991). The court of appeals reasoned that the rule improperly restricted the exemption's availability and then addressed NAC's claim for a tax exemption under the statute. Newspaper Agency Corp., 892 P.2d at 21-22. It concluded that the purchases in question were made for "new or expanding operations" under the plain terms of section 59-12-104(16) and were therefore entitled to a sales tax exemption. Id. at 22-23. We reverse.