JUSTICE COATS
announced the judgment of the Court and delivered an opinion,
in which JUSTICE MÁRQUEZ and JUSTICE BOATRIGHT join.
¶1 Denver petitioned for review of the court of appeals opinion reversing the judgment of the district court and remanding with directions to vacate the subject tax assessments against Expedia and the other respondent online travel . companies (“OTCs”). See Expedia, Inc. v. City & Cty. of Denver, 2014 COA 87, 405 P.3d 251. The district court had. largely upheld a Denver hearing officer’s denial' of protests by Expe-dia and the other OTCs to Denver’s claim for unpaid taxes, interest, and penalties, assert-edly due according to Denver’s ordinance imposing a lodger’s tax, Unlike the hearing officer and district court, the court of appeals concluded that the city lodger’s tax article was at least ambiguous with regard to both the purchase price paid or charged for lodging, upon which the tax is tó be levied, and the status of the OTCs as vendors, upon which the ordinance imposes the responsibility to collect the tax and remit it to the city; and the intermediate' appellate court considered itself obligated to resolve all ambiguities in the lodger’s tax article, being a tax statute, in favor of the OTCs.
¶2 The application of well-accepted aids to statutory construction leads to the conclusion that the fair and reasonable interpretation of Denver’s lodger’s tax article is that it imposes a duty on the OTCs to collect and remit the prescribed tax on the purchase price of any lodging they sell, to include not only the amount they have contracted with the hotel to charge and return but also the amount of their markup. The judgment of the court of appeals is therefore reversed, and the matter is remanded for consideration of the remaining issues raised oh appeal by the parties.
I.
¶3 In July 2010, the City and County of Denver issued nine Notices of Final Determination, Assessment and Demand for Payment against various online travel companies: Expedia, Inc.; Hotels.com LP; Hotwire, Inc.; Orbitz, LLC; Trip Network, Inc.; Price-line.com Incorporated; Travelweb, LLC; Site59.com, LLC; and Travelocity.com LP. The Notices claimed unpaid taxes, penalties, and interest due according to the city lodger’s tax article, Denver Revised Municipal Code (“D.R.M.C.”) §§ 53-166 to -236, for the period from January 2001 through April [1130]*11302010, totaling over $40 million.1 These online companies filed nearly identical protests, requesting hearings before a Denver Department of Finance hearing officer, and the protests were consolidated by stipulation.
¶4 Based on the stipulated evidence, including depositions and other materials from litigation in other jurisdictions and internal materials of the OTCs themselves explaining their operational methods and practices, the hearing officer found, and the parties do not dispute, that the OTCs operate under two basic business models. Under what they describe as the “agency model,” he found that the OTCs refer customers to hotels. Lodgers then transact directly with the hotels, and the OTCs receive commissions in separate transactions. Under what they describe as the'“merchant model,” by contrast, the OTCs operate in the transaction somewhere between lodgers and hotels. Lodgers transact with the OTCs, prepaying for reservations, and the OTCs later pass part of those payments along to the hotels. The OTCs, not the hotels, appear as the merchant of record on lodgers’ credit card statements — hence the term “merchant model.” These two models have different pricing structures, about which again the parties do not disagree. In the agency model, the hotels maintain exclusive control over the purchase price paid by lodgers. In the merchant model, by contrast, the hotels set a rate they will accept, which the OTCs refer to as a “net rate,” but the hotels grant the OTCs discretion, within designated limits, to set the price ultimately to be paid by the lodger. The OTCs then sell reservations to lodgers at that price, pass the amount of the so-called “net rate” plus a tax surcharge along to the hotels, and retain the difference as their own compensation.
¶5 For agency-model transactions, the hotels collect and remit lodger’s taxes, just as they do for all other traditional bookings.2 For merchant-model transactions, the hotels, as a matter of practice, have also been claiming the transactions on their own lodger’s tax returns, but because the hotels do not transact directly with the lodgers, and because the hotels typically do not receive payment at the time of the transaction with the lodger, the process of collecting and remitting the lodgers’ tax to the city is, in current practice, somewhat more convoluted. In practice, the OTCs typically collect a “surcharge” from the lodger at the time the lodger initially pays for a reservation. The OTCs then transmit that tax surcharge to the hotel along with the so-called “net rate,” which transmission ordinarily occurs after the lodger checks out. Finally, the hotel remits the surcharged amount to the city, along with its other lodger’s tax receipts for the month.
¶6 When booking reservations, the OTCs typically disclose two charges to lodgers. The first amount is the room rate; which is presented to the lodger as a single per-night rate that includes both the discounted rate to be returned to the hotel and the OTC’s markup on that rate. The second amount is a taxes-and-fees charge, which is presented to the lodger as a single per-transaction amount but which actually has two components: what the OTCs refer to as a “service fee” and a surcharge for taxes.3 Typically, the parties agree, the tax surcharge is computed on the “net rate,” while the service fees are computed on the price charged to the lodger plus taxes.
¶7 To illustrate, Denver relied on the following example during administrative proceedings, using hypothetical numbers from the deposition of Expedia, Inc.’s corporate [1131]*1131representative. Assume a website sells a reservation for $100, of which $75 will be paid to the hotel as the net rate and $25 will be retained by the OTC as its markup. If the applicable lodger’s tax is 10%, it will be applied to the $75 net rate and the tax surcharge will therefore be $7.50. If the OTC’s service charge is 5.5%, it will be applied to the so-called “retail price” plus taxes — i.e., to $107.50 — and the service fee will therefore be $5.91. The lodger will see a room rate of $100 and a taxes-and-fees charge of $13.41,‘and will pay a total of $113.41. The'OTC will retain both the markup and the service fee ($25 plus $5.91, totaling $30.91)4 and will eventually remit to the hotel the “net rate” and tax surcharge ($75 plus $7.50, totaling $82.60). The hotel then will remit the tax receipts ($7.50) on its next monthly lodger’s tax return.
¶8 The hearing officer held that this practice for merchant-model transactions does not comport with the mandates of the city lodger’s tax article for two reasons. First, he concluded that the OTCs’ markups and service fees are “directly connected with” furnishing lodging, as contemplated by section 53471(e) of the D.R.M.C., and therefore must be included within the tax base. Second, he concluded that the OTCs are “vendors,” within the contemplation of section 53-170(8), and are therefore responsible for collecting and remitting taxes directly to the city. The hearing officer therefore upheld Denver’s Notices.5
¶9 The OTCs sought judicial review as permitted by C.R.C.P. 106(a)(4). The district court rejected Denver’s position regarding the applicable statute of limitations, holding instead that Denver could assert liabilities for only the preceding three years, but other,wise it upheld the hearing officer’s determinations. On cross-appeals by the parties, the court of appeals concluded that the city lodger’s tax article is at least ambiguous as to both the question whether the ■ OTCs áre “vendors,” with eollect-and-remit obligations, and the question whether the tax base includes the OTCs’ markups and service fees. Relying on its understanding that tax statutes must be construed strictly, the intermediate appellate court construed both provisions against the promulgating authority and ordered the case remanded with directions to vacate Dénver’s Notices.6
¶10 Denver petitioned this court for a writ of certiorari.
II.
1Í11 By ordinance, the City and County of Denver imposes a tax on the privilege of purchasing lodging in the city, and the tax thus imposed is to be paid by the person exercising the privilege. - D.R.M.C. § 53-171(a). The amount of the tax is to be calculated as a percentage of the purchase price paid or charged for purchasing the lodging, § 53471(b), and obligations are imposed on the vendor to add the amount of this tax to the purchase price or charge for lodging and pay to the city, on a monthly basis, an amount equivalent to the tax on all gross taxable sales, § 53474(a).
1Í12 The term “purchase or sale” is used as a term of art in the lodger’s tax article to mean the acquisition or furnishing of lodging within the city for consideration. See § 53-170(4). Similarly, the term “lodging” is used as a term of art in the article to refer-to rooms or accommodations for overnight use furnished to someone who has for consideration acquired the right to use, possess, or occupy any such room or accommodation in-[1132]*1132either a hotel or another of the enumerated similar establishments, under a concession, permit, lease, contract, license to use, or other similar arrangement. § 53-170(2). Finally, the term “vendor,” as it is used in the lodger’s -tax article, refers - specifically to a person making sales of lodging, or furnishing lodging, to a purchaser in the city. § 58-170(8).
¶13 No claim that the city’s lodging tax article is unconstitutional, is preempted by statute, or is otherwise inoperable was implicated by the court of appeals judgment below. Therefore the questions pending before this court, concerning whether the OTCs are vendors and, if so, whether the purchase price upon which the lodging tax is to be calculated includes the OTCs’ markup, turn entirely on the interpretation of the Denver lodger’s tax article.
¶14 Like state statutes, city ordinances are a form of legislation and therefore have meaning according to the intent of the enacting body, as that intent is expressed in the language the enacting body has chosen for the particular ordinance itself. Dep’t of Transp. v. Gypsum Ranch Co., 244 P.3d 127, 131 (Colo. 2010); City of Colorado Springs v. Securcare Self Storage, Inc., 10 P.3d 1244, 1248 (Colo. 2000). If an ordinance or statute is clear and unambiguous, and is not in conflict with another ordinance or statute, it must simply be applied as written. Holcomb v. Jan-Pro Cleaning Sys. of S. Colo., 172 P.3d 888, 890 (Colo. 2007). However, if the language in which- legislation is written is susceptible of more than one reasonable interpretation, and is therefore considered ambiguous, a substantial body of interpretative aids, either provided by the legislative body itself to explain its own drafting conventions and preferences for avoiding or resolving conflict, see, e.g., D.R.M.C. §§ 1-3 to -12, or developed by courts over centuries, see generally Norman J. Singer & J.D. Shambie Singer, Sutherland Statutes & Statutory Construction (7th ed. 2007), is. available to help determine which of these reasonable interpretations actually embodies the legislative intent. People v. Jones, 2015 CO 20, ¶ 10, 346 P.3d 44, 48.
¶15 These interpretative aids, or -canons of construction, may take a number of different forms. As we have noted in the past, many reflect little more than grammatical or syntactical conventions; others largely -reflect conventions followed in the process of legislative drafting; and still others purport to draw reasonable inferences from the l’elationship between legislative enactments and external events,.or actually seek to reconstruct the purpose of drafters, sponsors, or even individual supporters with regard- to legislative enactments. See Union Pac. R.R. v. Martin, 209 P.3d 185, 188 (Colo. 2009). Noteworthy for understanding. the meaning of the tax provisions at issue here, a number of court-developed aids, or rules of construction, also express presumptions, or preferences, favoring, in the absence of adequate indication to the contrary, one over another class of litigants affected by the specific type of legislation at issue.
¶16 Included in this last group are policy preferences concerning the construction of statutes imposing burdens on property or liberty. In this jurisdiction, we have long accepted the proposition that statutes imposing a tax burden on. the citizenry should be construed strictly, resolving doubts concerning their meanings in favor of the persons against whom an attempt is made to exact the tax. Gomer v. Chaffee, 6 Colo. 314, 317 (1882) (“It is a settled rule in the interpretation of revenue laws, that in case of doubt or ambiguity the construction must be in favor of the public.” (citing Thomas M. Cooley, Law of Taxation 197-208 (1876, reprinted 1881))). Much like the closely related policy favoring lenity in the construction of criminal statutes, see Commissioner v. Acker, 361 U.S. 87, 91, 80 S.Ct. 144, 4 L.Ed.2d 127 (1959) (applying rule of lenity to civil tax penalties), 'however, this policy preference regarding tax burdens was never intended to displace other canons designed to help resolve doubts, or ambiguity. See, e.g., Douglas Cty. Bd. of Equalization v. Fid. Castle Pines, Ltd., 890 P.2d 119, 125-30 (Colo. 1995) (stating that “[generally, we interpret ambiguous tax statutes in favor of the taxpayer,” but also applying several other canons of construction and surveying legislative history); Stanley v. Little Pittsburg Min. Co., 6 Colo. [1133]*1133415, 419 (1882) (citing Cooley, supra, for the proposition that the presumption exists to maintain fidelity to legislative intent); cf. White v. United States, 305 U.S. 281, 292, 59 S.Ct. 179, 83 L.Ed. 172 (1938) (“It is the function and duty of courts to resolve doubts. We. know of no reason why that function should be abdicated in a tax case.,., Here doubts which may arise upon a cursory examination of §§ 101 and 1.15 disappear when they are read, as they must be, with every other material part of the statute, and in the light of their legislative history,” (citation omitted)).
¶17 Rather, such policy preferences have often been characterized as rules of last resort, applicable only if, after utilizing the other relevant aids to statutory construction, the enacting body’s intent remains obscured. See, e.g., People v. Thoro Prods. Co., 70 P.3d 1188, 1198 (Colo. 2003) (quoting from Muscarello v. United States, 524 U.S. 125, 138, 118 S.Ct. 1911, 141 L.Ed.2d 111 (1998), to the effect that the “rule of lenity applies only if, after seizing everything from which aid can be derived, ... we can make no more than a guess as to what Congress intended,” and from United States v. Wilson, 10 F.3d 734, 736 (10th Cir. 1993), to the effect that the “rule of lenity is a rule of last resort, to be invoked only after traditional means of interpreting the statute have been exhausted”); BP Am. Prod. Co. v. Patterson, 185 P.3d 811, 814 (Colo. 2008) (holding that rule favoring longer, rather than shorter, of two arguably applicable statutes of limitation, like analogous rules of choice applicable to statutes or contractual provisions generally, is a rule of last resort); cf. Lee.R. Russ & Thomas F. Segalla, Couch on Insurance § 22:16 (3d ed. ■1995) (characterizing the familiar principle that ambiguity in insurance contracts must be construed in favor of insured as a rule of last resort).7
¶18 It is also widely accepted that where the body enacting particular legislation has not' expressly defined a térm or otherwise limited its’ meaning, that term ■must be given its ordinary .meaning. See Taniguchi v. Kan Pac. Saipan, Ltd., 566 U.S. 560, 565-67, 132 S.Ct. 1997, 2002, 182 L.Ed.2d 903 (2012); Marquez v. People, 2013 CO 58, ¶ 8, 311 P.3d 265, 268. Because, however, terms frequently-have more than one ordinary meaning, or at least more than one. shading or nuance of meaning, and because even a dictionary definitiqn broad ■enough to encompass a particular sense of a word does not establish that the term is ordinarily understood, in that sense, Taniguchi, 566 U.S. at 567-69, 132 S.Ct. at 2003, the precise meaning intended by an undefined term often must be determined by reference to other considerations,, like the context in which it is used and the apparent purpose for its use, Marquez, ¶ 8, 311 P.3d at, 268; see also Curious Theatre Co. v. Colo. Dep’t of Pub. Health & Env’t, 220 P.3d 544, 549 (Colo. 2009). In particular, we have often held that in the absence of some express indication to the contrary, a term or provision that is part of a greater statutory scheme should be interpreted, to the extent possible, harmoniously with.the other provisions and purpose [1134]*1134of that scheme. Gypsum Ranch Co., 244 P.3d at 131; Frank M. Hall & Co. v. Newsom, 125 P.3d 444, 448 (Colo. 2005). In this regard, a tax statute is no different from any other statute. Welby Gardens v. Adams Cty. Bd. of Equalization, 71 P.3d 992, 995 (Colo. 2003); see also Walgreen Co. v. Charnes, 819 P.2d 1039, 1043 & n.6 (Colo. 1991) (requiring that particular Denver sales tax ordinance be construed in pari materia with entire scheme to effectuate the legislative intent).
¶19 The two issues resolved by the court of appeals by construing the lodger’s tax article, or better, by declining to fully construe the lodger’s tax article and instead resolving any perceived ambiguity in favor of the taxpayer, analytically involve one-substantive question, concerning tax liability, and a separate administrative question, concerning the responsibility to collect whatever tax is due and remit it to the city. While it might appear that the more logical sequence for dealing with these two questions would be to address the existence and extent of any tax liability before assigning responsibility for its collection and remittance, perhaps because only assessments against the OTCs are at issue in this litigation and therefore a determination that they are not' responsible to collect or remit any lodging tax should end the matter, the parties and the intermediate appellate court have not addressed the issues in that sequence. For that reason, and because we believe the purchase price of lodging, or tax base, to be integrally related to the sale, and therefore the seller, or “vendor,” of that lodging, we will follow suit and address the administrative question first.
A.
¶20 Although the tax is imposed on the purchaser, the obligation to collect it and remit it to the city falls on the vendor, and -for that reason, the court of appeals appropriately concerned itself with the definition of “vendor” in the article. It determined that according to the article’s definition, the term “vendor” refers to a person who furnishes lodging, and since the lodger’s tax article itself nowhere defines the term “furnish,” the court turned to dictionary definitions of that term and case law in other contexts to determine its ordinary meaning. Further finding that the OTCs’ -primary contention — that the person who furnishes lodging is the one who actually provides access to a specific room— was at least a reasonable interpretation of the article, the intermediate appellate court considered itself bound to accept that interpretation.
¶21 While the article somewhat unusually defines “purchase or sale” as a single term, there appears to be ho dispute that it can only be understood to intend that “purchase” refers to the acquisition of lodging within the city by any person for consideration, and that “sale” refers to the furnishing of lodging within the city by any person for consideration. See § 53-170(4). That being the case, the court of appeals was undoubtedly right in concluding that the word “or” in the definition of “vendor” was not used in its disjunctive implication but rather to introduce a synonymous phrase. See People v. Swain, 959 P.2d 426, 430 n.12 (Colo. 1998) (“Generally, the word ‘ori is a disjunctive particle that denotes an alternative; however, the word ‘or’ may also be utilized as a ‘coordinate' conjunction introducing a synonymous word or phrase or it may join different terms expressing the same idea or thing,’ ” (quoting State v. Ramsey, 311 S.C. 555, 430 S.E.2d 511, 514 (1993))). As the definition of “sale” makes clear, furnishing lodging to a purchaser is simply the equivalent of, or another way of saying, making a sale of lodging. By concluding, however, that a “vendor” is therefore one who merely “furnishes lodging,” the court of appeals too narrowly circumscribed the equivalent definitions and thereby mistakenly considered itself free to look to the “ordinary meaning” of the term “furnish.”
¶22 Read together, the definitions of “purchase or sale” and “vendor” unmistakably lead to-the conclusion that the term “vendor” does not refer simply to someone who furnishes lodging, as the court of appeals reasoned, but rather to someone who furnishes lodging for consideration, and further, only to someone who furnishes lodging for consideration to a person who acquires that lodging for that consideration. See § 53-170(4), (8). Making a sale of lodging, or furnishing it for consideration, on the one hand, and purehas-[1135]*1135ing that lodging, or acquiring it for consideration, on the other, are defined as opposite but correspondin'g aspects, or what could be characterized as flip-sides, of the same transaction. While the term “furnish” may not be separately defined in the article, as the court of appeals and OTCs correctly point out, the phrase “furnishing lodging to a purchaser,” appearing in the- definition of “vendor,” is made synonymous with “making sales” of lodging, as the court of appeals also explains. “Furnishing lodging,” as used in the definition of “vendor” therefore cannot mean simply providing a room, in the sense of controlling physical access to it, but can only mean making a sale of lodging.
¶23 By contrast with the term “furnish,” the term “lodging” is expressly defined as a term of art; and that definition similarly makes clear that furnishing lodging refers to selling, or providing for consideration, “the right to use, possess, or occupy qualifying accommodations.” While the definition might have been phrased more felicitously in terns of the overnight use of certain rooms or accommodations, rather than as “rooms or accommodations for overnight use,” when the definition is read as whole and in context, the choice of subject and placement of a modifying prepositional phrase creates no ambiguity. There can be no serious question that “lodging” does not refer to a room, as a commodity, or even title or a right of ownership of a room, but rather to the right of overnight use of rooms meeting all of the specifications of the definition. Because only the right to overnight use of rooms can be furnished and acquired for consideration without removing the transaction from the definition of “lodging” altogether, furnishing lodging for consideration necessarily refers to selling, or providing for consideration, the right to overnight use of rooms or accommodations in the enumerated hotel-like facilities,
¶24 Although ⅞6 OTCs maintain that even in merchant-model transactions they do not sell, or furnish for consideration, a right to occupy or use the hotel rooms in question, no matter what terminology they may choose to use in describing their transactions, as a functional matter that is precisely what they do. See Apollo Stereo Music Co. v. City of Aurora, 871 P.2d 1206, 1211-12 (Colo. 1994) (holding that vending-machine owners, rather than owners of stores in which vending machines sit, are the vendors for purposes of sales taxes in light of the control they actually exercised over the machines, and especially over the access to and distribution of the moneys deposited in the machines); People v. Becker, 159 Colo. 562, 413 P.2d 185, 186 (1966) (“It is a familiar and well documented rule of law that taxation is concerned with realities and that, in considering tax matters, substance and not form should govern”).
¶25 However characterized, virtually every aspect of the merchant-model transaction objectively places an OTC in the role of “vendor.” The OTC deals directly in the transaction with the consumer-purchaser. The OTC sets the price, or consideration, without the payment of which, the OTC will not sell the consumer the right to use the room; the OTC collects the amount of that purchase price directly from the consumer; and the OTC adds to the purchase' price an amount it determines to be sufficient for the lodger’s táx. Whether or not a particular room is specified at that point, in accepting the purchase price the OTC sells a reservation for a room of particular specifications to a consumer, and by its arrangement with the hotel, the hotel becomes contractually obligated to the OTC to provide the consumer with a room meeting those specifications.
¶26 Although the OTCs may choose to characterize themselves as mere intermediaries in a transaction between the hotels and the consumers, their relationship with the hotels is clearly not one remotely resembling an agency relationship. The OTCs • are not employed by the hotels nor are they paid a fee, or commission, by the hotels for arranging reservations, as in the traditional agency model. The obligations of the OTCs and hotels to each other are purely contractual in nature, and to the extent the purchaser of lodging acquires rights from the hotel, it is at most as a third-party beneficiary of the contractual arrangement between the hotel and OTC. Whoever may actually hand the purchaser the key, the lodger is the purchaser in a transaction of sale with the OTC.
[1136]*1136¶27 By the same token, however, although the OTCs¡ pay an amount that is set by the hotels to them for each room reservation the OTCs make, and contractually retain the right to charge more in their subsequent sales to lodger-purchasers, neither are their arrangements with the hotels in the nature of wholesale purchases. The OTCs’ separate transactions, first with the hotels and then with lodgers, are not in the nature of wholesale and retail sales for the simple reason that the OTCs never acquire the right to occupy or use the rooms in question, They merely contract for the authority to sell to consumers,- or lodgers, the right to occupy or use rooms, in agreed upon numbers or as available, at a price largely of their own choosing, in exchange for an agreement to return a specified amount to the hotels for each reservation not timely cancelled. If the OTCs actually purchased the right to. occupy or use the rooms at a wholesale rate and resold that right at a retail rate, in the absence of some other provision in the tax code,. as provided for various commodity sales, the first sale would itself be a taxable event, with .a second sale resulting in at least partial double taxation.8
¶28 The lodger-purehaser in the transaction is in privity of contract with the OTC, not file hotel. By virtually all objective criteria, the contract for sale of the right to use a hotel accommodation is entered into by the OTC and purchaser, at the time of the OTC’s acceptance by receiving payment of the amount it charges for the resérvation. There is of course nothing improper in attempting to structure transactions to the advantage of one’s clients, and within ethical limits, that is precisely what lawyers are typically retained to do. But labelling alone is insufficient to alter the structure of a transaction, Apollo Stereo Music Co., 871 P.2d at 1211-12; Becker, 413 P.2d at 186. If tax obligations are imposed on the basis of function, then objective criteria establishing the functional relationships involved in any particular transaction must be determinative of the relative tax obligations. Any fair and reasonable interpretation of the city lodger’s tax article categorizes the OTC in a merchant-model transaction, according to the objective criteria of the article’s definitions, as the vendor, with the obligation to collect and remit a lodger’s tax to the city.
B.
¶29 Not only ⅛ the lodger’s tax imposed on the person actually purchasing lodging in the city, but the amount of the tax thus imposed is expressed as a percentage “of the price paid or charged” for the purchase in question. § 53471(a), (b). For the obvious reasons that a single money transaction may involve the purchase and sale of more than lodging alone and that a vendor may attempt to differentiate the cost of lodging and the cost of related goods or services for tax purposes, despite their inseparability from the purchase and sale of the lodging itself, the article further specifies that “the price paid by the purchaser for any goods, services or commodities other than those directly connected with,, and included in the price of, the furnishing of rooms or accommodations” is not to be included as part of “the purchase price” from which the lodger’s tax is to be calculated. § 53471(c). The court of appeals focused .on the meaning of the phrase “directly connected with” in the ordinance, and because it had already found it reasonable to conclude that the OTCs do not furnish lodging at all, it similarly considered it reasonable to conclude that the OTCs’ markups, which they characterize as'compensation for providing travel-related information and online facilitation services, are not directly connected with furnishing lodging.
•¶30 Because we reach a different conclusion with regard to the meaning of “furnishing” and therefore the OTCs’ role- in furnishing lodging, we must similarly find the intermediate appellate court’s resolution of the tax base question, based on its understanding of the meaning of “furnishing,” to be unsupported by the text of the article. The appellate court was, however, undoubt: edly correct in inferring from the context a [1137]*1137relationship between the purchase price charged for lodging and the vendor charging that.price. If, as we now make clear, the OTC is actually the vendor, in- a merchant-model transaction, making sales of lodging by. exchanging the right to use or occupy a room for the purchaser’s payment of the price the OTC has decided to charge for the use of that room, it would not be unnatural for the tax scheme to intend by the “purchase price paid or charged,” the price assessed by the OTC, without the payment of which the OTC would not sell, and the purchaser could not acquire, the room reservation in question.
¶31 In emphasizing that certain “goods, services or commodities” are not to be considered part of the “purchase price paid or charged for lodging,” for lodger’s tax purposes, the article circumscribes the exempted “goods, services or commodities” with the limiting phrase, “other than those directly connected with, and included in the price of, the furnishing of rooms or accommodátions.” There is no dispute that the cost of goods, services, and commodities other than those specifically excluded according to this formula are instead to be taxed as part of the purchase price paid or charged for the lodging. Beeghly v. Mack, 20 P.3d 610, 613 (Colo. 2001) (“Under the rale of interpretation ex-pressio unius exdusio alterius, the inclusion of certain items implies.the exclusion of others.”). While the word “and” is typically, and perhaps even presumptively, used as- a coordinating conjunction, joining,two elements of identical construction and equal grammatical rank, it is also a word long acknowledged to serve a wide-range of different functions, depending upon syntax and context. See, e.g., Clyncke v. Waneka, 157 P.3d 1072, 1079 (Colo. 2007) (Coats, J., concurring) (quoting Peacock v. Lubbock Compress Co., 252 F.2d 892, 893 (5th Cir. 1958), to the effect that “and” is a word having no “single meaning, for chameleonlike, it takes its color from its surroundings”); see generally 2 Corpus Juris 1337 (1916) (stating, in definition of “and,” that “[wjhile the word is generally used in a conjunctive sense, this is not its invariable use; it is often employed to indicate á connection of what follows with what has gone before in the way of narration or description”)..
¶32 As the Denver ordinances themselves expressly contemplate, the words “and” and “or” may be functionally interchangeable, depending upon context and usage in a given sentence. See D.R.M.C. § 1-2(10) (“ ‘Or’ may be read ‘and,’ and ‘and’ may be read ‘or,’ if the sense requires it.”). More subtly, however, even when a conjunctive, rather than disjunctive, meaning is clearly intended, a number of different relationships may be intended between the conjoined elements. The conjoined elements may be completely independent or synonymous, but often their meanings overlap with one, or both, serving to further define or clarify the sense in which the other is being used. See Arthur v. Cumming, 91 U.S. 362, 364, 23 L.Ed. 328 (1875) (noting “many instances in which two phrases with the like conjunction between them have been used to designate the same thing,” a construction “obviously done to make clear and certain the meaning of the legislature, and to leave no room for doubt upon, the subject”).
¶33 While the use of commas to set off the second conjoined, phrase — “and included in the price of’ — suggests that it was intended to operate in apposition to, or. as the functional equivalent of, the first phrase — “directly connected with” — the meaning of both phrases is ultimately dictated by. context and their use specifically in reference "to the “furnishing of rooms or accommodations.” "See United States v. Ron Pair Enters., Inc., 489 U.S. 235, 251, 109 S.Ct. 1026, 103 L.Ed.2d 290 (1989) (“Although punctuation is not controlling, it can provide useful confirmation of conclusions drawn from the words of a statute.”). For the" reasons we have already articulated, the term “furnishing” in' this context means making sales of, or selling, the right of overnight use of rooms or accommodations constituting lodging. There can therefore at least be little doubt that the purchase price of services directly connected with and included in the price for which the lodging in question is sold is to be included in the tax base.
¶34 Whether or not the conjoined conditions of being directly connected with and [1138]*1138being included in the selling price of the lodging are precisely synonymous, they are clearly attempts to describe a determinable amount that is neither based on the fortuity of being included in a single payment by the purchaser nor subject to manipulation by the labelling choices of the vendor. Cf. Apollo Stereo Music Co., 871 P.2d at 1211-12; Becker, 413 P.2d at 186. Functionally, the selling, and therefore purchase, price of lodging is the amount -without the payment of which the lodging will not be furnished by sale, and therefore cannot be acquired by purchase. However this amount is broken out, or characterized, in the billing process, if the purchaser has no option but to pay it to the vendor as part of the purchase of the lodging in question, it is necessarily both included in and directly connected with the price for which that lodging is sold.
¶35 In the typical merchant-model transaction, as described for purposes of these proceedings, the OTC’s markup is not distinguished in the billing process from the amount to be returned to the hotel at all, much less charged as a separate fee for informational and online sérvices. However, whether or not such a fee could be objectively justified in terms of the service provided, because the purchaser has no option to decline it in making his purchase of lodging from the OTC, and it is therefore inseparable from the selling price of the lodging, it is directly connected with, in the sense that it is necessarily included in, that selling price. When the related provisions and interlocking definitions of the lodger’s tax article are considered as a harmonious whole, the conclusion that the OTC’s markup must be included in the purchase price paid or charged for lodging is not only one reasonable construction of the article; it is sufficiently apparent that it is the fair and reasonable construction embodying the legislative intent.
III.
¶36 Because the application of well-accepted aids to statutory construction leads to the conclusion that the fair and reasonable interpretation of Denver’s lodger’s tax article is that it imposes a duty on the OTCs to collect and remit the prescribed tax on the purchase price of ány lodging they sell, to include not only the amount they have contracted with the hotel to charge and return but also the amount of their markup, the judgment of the court of appeals is reversed, and the matter is remanded for consideration of the remaining issues raised on appeal by the parties.
JUSTICE HOOD concurs in the judgment.
JUSTICE GABRIEL dissents, and CHIEF JUSTICE RICE and JUSTICE EID join in the dissent.