MICHAEL A. WOLFF, Judge.
This petition to review a decision of the Administrative Hearing Commission raises two issues: First, does Westwood Country Club owe sales tax on its purchases of food for members’ meals when such meals are excluded from sales tax since they are not “sales at retail?” Second, are the fees charged by Westwood for the use of golf carts on its premises subject to sales tax? We hold: (1) Since meals and beverages served by Westwood are not “sales at retail,” Westwood must pay sales tax on its purchases of food and beverages for such service; and (2) Since Westwood has paid sales tax on its purchases of golf carts, Westwood does not owe sales tax on fees that the club charges to members for use of the carts.
Westwood is a private country club located in St. Louis County, Missouri, offering its members and guests golf, tennis, dining and other activities. It is not open to the public. Westwood purchases food that it prepares and serves to members and guests as meals. Since Westwood does not regularly serve meals and beverages to the public, its services to members and guests are excluded from sales tax. Greenbriar Hills Country Club v. Director of Revenue, 935 S.W.2d 36, 38 (Mo. banc 1996). Westwood charges a fee for the use of golf carts to its members and their guests.
The department of revenue required Westwood to pay sales tax of $2,846.02 on food purchases and cart fees for January of 1998 and assessed a similar tax of $1,411.84 for February of 1998. Westwood appealed to the commission, which found that Westwood owed no sales tax. Now, the director seeks review of the commission’s decision.
Taxation of Westwood’s Food Purchases
The first issue is whether the food Westwood purchases to prepare and to serve to members and guests is subject to sales tax. Under Greenbriar Hills, no sales tax is charged on these meals since Westwood does not regularly sell meals to the public. 935 S.W.2d at 38. The commission’s decision exempted Westwood from paying tax on its food and beverage purchases. We reverse the commission and hold that Westwood is subject to the sales tax on its purchases of food and beverages for consumption by its members and their guests.
By state regulation, sales tax is due on such purchases: “If a club does not regularly serve food and beverages to the public, other than its members and their guests, and the club acts as a cooperative association for the benefit of its members,1 [887]*887the club has the option of either collecting and remitting sales tax on its sales to members and guests or paying sales tax on the club’s purchases of food and beverages (see section 144.020.1(6), RSMo).” 12 CSR 10-3.048(7) (1998)(emphasis added).2 The portion of the regulation giving the club the option to collect the tax on sales to members and their guests is no longer operative. Greenbriar Hills, 935 S.W.2d at 38. However, the regulation does recognize that food purchased by the club for serving its members and guests is subject to tax at some point. Here, Westwood must pay sales tax on its purchases of food and beverages. In Greenbriar Hills, this sales tax on the country club’s purchases of food and beverages was properly due and paid. 935 S.W.2d at 37.
Westwood here claims the benefit of two statutory provisions: (1) that its purchases were for resale, and (2) that its purchases were of materials used in processing goods into new personal property to be sold for final use or consumption. The first is an exclusion, and as in Greenbriar Hills, the question is whether, by ordinary principles of statutory construction, the sales tax law excludes from its definitions the transactions involved here. The second point claims the benefit of a specific statutory exemption. Exemptions from taxation are to be strictly construed, State ex rel. Transp. Mfg. & Equip. Co. v. Bates, 359 Mo. 1002, 224 S.W.2d 996,1000 (banc 1949), and, as such, it is the burden of the taxpayer claiming the exemption to show that it fits the statutory language exactly.
(1) Goods Purchased for Resale
Westwood argues that the club merely purchased the food and beverages for resale and its purchases were not subject to tax, under McDonnell Douglas Corp. v. Director of Revenue, 945 S.W.2d 437 (Mo. banc 1997), because section 144.010(9)3 excludes from taxation goods to be resold at retail. Dean Machinery Co. v. Director of Revenue, 918 S.W.2d 244, 245-246 (Mo. banc 1996).
Westwood’s members are excluded from paying sales tax on food and meals under Greenbriar Hills. 935 S.W.2d at 38. The outcome in Greenbriar Hills was predicated on the maxim of expressio unius est exclusio alterius ;4 since the statute imposed a tax on meals and beverages served at eateries open to the public, those that did not regularly serve the public were excluded by negative implication. Section 144.010.1(9) broadly defines “sales at retail” of tangible personal property for use or consumption but excludes such property that is for “resale.” However, since West-wood’s service of food and beverage is not a sale at retail, Westwood’s purchases do not fit the exclusion. Westwood’s purchases are thus subject to the sales tax.
The dissent questions why this case is not governed by McDonnell Douglas. McDonnell Douglas addresses exemptions from use tax. 945 S.W.2d at 439-440. The statutory exemption for a sale to the federal government specifically classifies the sale as a “retail sale which the state of Missouri is prohibited from taxing pursuant to the Constitution or laws of the United States.” Section 144.030.1. Where aircraft are sold to non-exempt entities, of course, a sales or use tax is to be collected on the sale of the final product. Director of Revenue v. Superior Aircraft Leasing Co., Inc., 734 S.W.2d 504-505, 507-508 [888]*888(Mo. banc 1987).5 Here, however, there is no sale at retail, as Greenbriar Hills holds. 935 S.W.2d at 38. The exclusion of goods for resale is contained in section 144.010.1(9), which defines “sale at retail.” Put simply, there must be a “sale at retail” in order for the “resale” exclusion of that section to apply.
(2)Component or Ingredient Materials Used in Making New Goods
Westwood further argues that its food and drink purchases are exempt under section 144.030.2(2). The statute exempts component or ingredient materials used in the “manufacturing, processing, compounding, mining, producing or fabricating” of goods into “new personal property ... intended to be sold ultimately for final use or consumption.” The commission determined that Westwood was engaged in the process of converting raw foodstuffs into the final product of meals and drinks and applied Al-Tom Inv., Inc. v. Director of Revenue,
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MICHAEL A. WOLFF, Judge.
This petition to review a decision of the Administrative Hearing Commission raises two issues: First, does Westwood Country Club owe sales tax on its purchases of food for members’ meals when such meals are excluded from sales tax since they are not “sales at retail?” Second, are the fees charged by Westwood for the use of golf carts on its premises subject to sales tax? We hold: (1) Since meals and beverages served by Westwood are not “sales at retail,” Westwood must pay sales tax on its purchases of food and beverages for such service; and (2) Since Westwood has paid sales tax on its purchases of golf carts, Westwood does not owe sales tax on fees that the club charges to members for use of the carts.
Westwood is a private country club located in St. Louis County, Missouri, offering its members and guests golf, tennis, dining and other activities. It is not open to the public. Westwood purchases food that it prepares and serves to members and guests as meals. Since Westwood does not regularly serve meals and beverages to the public, its services to members and guests are excluded from sales tax. Greenbriar Hills Country Club v. Director of Revenue, 935 S.W.2d 36, 38 (Mo. banc 1996). Westwood charges a fee for the use of golf carts to its members and their guests.
The department of revenue required Westwood to pay sales tax of $2,846.02 on food purchases and cart fees for January of 1998 and assessed a similar tax of $1,411.84 for February of 1998. Westwood appealed to the commission, which found that Westwood owed no sales tax. Now, the director seeks review of the commission’s decision.
Taxation of Westwood’s Food Purchases
The first issue is whether the food Westwood purchases to prepare and to serve to members and guests is subject to sales tax. Under Greenbriar Hills, no sales tax is charged on these meals since Westwood does not regularly sell meals to the public. 935 S.W.2d at 38. The commission’s decision exempted Westwood from paying tax on its food and beverage purchases. We reverse the commission and hold that Westwood is subject to the sales tax on its purchases of food and beverages for consumption by its members and their guests.
By state regulation, sales tax is due on such purchases: “If a club does not regularly serve food and beverages to the public, other than its members and their guests, and the club acts as a cooperative association for the benefit of its members,1 [887]*887the club has the option of either collecting and remitting sales tax on its sales to members and guests or paying sales tax on the club’s purchases of food and beverages (see section 144.020.1(6), RSMo).” 12 CSR 10-3.048(7) (1998)(emphasis added).2 The portion of the regulation giving the club the option to collect the tax on sales to members and their guests is no longer operative. Greenbriar Hills, 935 S.W.2d at 38. However, the regulation does recognize that food purchased by the club for serving its members and guests is subject to tax at some point. Here, Westwood must pay sales tax on its purchases of food and beverages. In Greenbriar Hills, this sales tax on the country club’s purchases of food and beverages was properly due and paid. 935 S.W.2d at 37.
Westwood here claims the benefit of two statutory provisions: (1) that its purchases were for resale, and (2) that its purchases were of materials used in processing goods into new personal property to be sold for final use or consumption. The first is an exclusion, and as in Greenbriar Hills, the question is whether, by ordinary principles of statutory construction, the sales tax law excludes from its definitions the transactions involved here. The second point claims the benefit of a specific statutory exemption. Exemptions from taxation are to be strictly construed, State ex rel. Transp. Mfg. & Equip. Co. v. Bates, 359 Mo. 1002, 224 S.W.2d 996,1000 (banc 1949), and, as such, it is the burden of the taxpayer claiming the exemption to show that it fits the statutory language exactly.
(1) Goods Purchased for Resale
Westwood argues that the club merely purchased the food and beverages for resale and its purchases were not subject to tax, under McDonnell Douglas Corp. v. Director of Revenue, 945 S.W.2d 437 (Mo. banc 1997), because section 144.010(9)3 excludes from taxation goods to be resold at retail. Dean Machinery Co. v. Director of Revenue, 918 S.W.2d 244, 245-246 (Mo. banc 1996).
Westwood’s members are excluded from paying sales tax on food and meals under Greenbriar Hills. 935 S.W.2d at 38. The outcome in Greenbriar Hills was predicated on the maxim of expressio unius est exclusio alterius ;4 since the statute imposed a tax on meals and beverages served at eateries open to the public, those that did not regularly serve the public were excluded by negative implication. Section 144.010.1(9) broadly defines “sales at retail” of tangible personal property for use or consumption but excludes such property that is for “resale.” However, since West-wood’s service of food and beverage is not a sale at retail, Westwood’s purchases do not fit the exclusion. Westwood’s purchases are thus subject to the sales tax.
The dissent questions why this case is not governed by McDonnell Douglas. McDonnell Douglas addresses exemptions from use tax. 945 S.W.2d at 439-440. The statutory exemption for a sale to the federal government specifically classifies the sale as a “retail sale which the state of Missouri is prohibited from taxing pursuant to the Constitution or laws of the United States.” Section 144.030.1. Where aircraft are sold to non-exempt entities, of course, a sales or use tax is to be collected on the sale of the final product. Director of Revenue v. Superior Aircraft Leasing Co., Inc., 734 S.W.2d 504-505, 507-508 [888]*888(Mo. banc 1987).5 Here, however, there is no sale at retail, as Greenbriar Hills holds. 935 S.W.2d at 38. The exclusion of goods for resale is contained in section 144.010.1(9), which defines “sale at retail.” Put simply, there must be a “sale at retail” in order for the “resale” exclusion of that section to apply.
(2)Component or Ingredient Materials Used in Making New Goods
Westwood further argues that its food and drink purchases are exempt under section 144.030.2(2). The statute exempts component or ingredient materials used in the “manufacturing, processing, compounding, mining, producing or fabricating” of goods into “new personal property ... intended to be sold ultimately for final use or consumption.” The commission determined that Westwood was engaged in the process of converting raw foodstuffs into the final product of meals and drinks and applied Al-Tom Inv., Inc. v. Director of Revenue, 774 S.W.2d 131 (Mo. banc 1989). Al-Tom involved an attempt to tax owners of Kentucky Fried Chicken franchises on the portion of oil not consumed in the frying of chicken and other foods. Id. at 131. “[I]f any part of a material is intended to and does remain as an essential or necessary element of the finished product then the entire purchase is exempt.” Id. at 134. Since the cooking oil was made an essential part of the fried foods, it was exempt from sales taxation. Id. at 135.
Al-Tom is distinguishable. As restaurants regularly open to the public, the Kentucky Fried Chicken franchises engage in “sales at retail” of food and beverages. Sections 144.010.1(9), 144.020.1(6). West-wood does not charge sales tax on meals and beverages it serves to members or their guests because there is no “sale at retail.” Greenbriar Hills, 935 S.W.2d at 38. Al-Tom avoids double taxation. Westwood wants the same principle to avoid being taxed even once.
The purpose of Missouri’s sales tax system is to tax property once and not at various stages in the stream of commerce. Dean Machinery, 918 S.W.2d at 245-46. Westwood, as a private club not open to the public, does not engage in sales at retail and, thus, does not charge members and guests sales tax on meals and beverages served to them. Westwood must, however, pay sales tax on its purchases of food and beverages.
The decision of the commission determining Westwood owed no sales tax on its purchases of food and beverages for members’ consumption is reversed.
Taxation of Golf Cart Fees
The commission determined that Westwood owed no sales tax on fees it charged for golf cart usage because West-wood previously paid sales tax on its purchases and leases of the carts. We agree and affirm this determination.
Section 144.020.1(8) imposes a tax on fees charged for the rental or lease6 of personal property unless the property was purchased under “sale at retail” conditions or sales taxes were previously paid by the renter or seller on the original purchase or lease of the property. The commission [889]*889determined that Westwood paid sales tax on its purchases or leases of golf carts. Therefore, under section 144.020.1(8), Westwood did not have to charge a sales tax on subsequent cart rentals to its members. The director urges that section 144.020.1(2) should be applied to the controversy. Section 144.020.1(2) imposes a sales tax on amounts paid for admission or fees paid to “any place of amusement, entertainment or recreation.... ” Fees paid to a country club are considered fees paid to a “place of amusement, entertainment or recreation.” Old Warson Country Club v. Director of Revenue, 933 S.W.2d 400, 403 (Mo. banc 1996). We, however, find that section 144.020.1(8) is a more specific statute than section 144.020.1(2) in that it expressly deals with the lease or rental of personal property upon which sales tax has already been paid. Since we apply a more specific statute over a more general statute when both address the same issue, we apply section 144.020.1(8) to the controversy. Greenbriar Hills, 935 S.W.2d at 38.
Missouri’s sales tax laws were designed to impose a tax on the retail sale or lease of personal property. Dean Machinery, 918 S.W.2d at 245. Since Westwood paid a sales tax on the golf carts when it purchased or leased them, the goal of taxing the purchase once and only once has been met. Id. at 246.
The commission’s decision denying taxation of food and beverage purchases is reversed; its decision that no tax is owed on golf cart fees is affirmed. The case is remanded.
PRICE, C.J., WHITE, HOLSTEIN AND BENTON, JJ., concur; LIMBAUGH, J., concurs in part and dissents in part in separate opinion filed; COVINGTON, J., concurs in opinion of LIMBAUGH, J.