See Sands, IA Sutherland Statutory Construction, pp. 186-187 (4th ed. 1972).The tax commissioner is empowered by Section 57-37-19, N.D.C.C., to make such rules and regulations as may be necessary for the interpretation and enforcement of Chapter 5737, N.D.C.C. The commissioner has promulgated North Dakota Estate Tax Rules and Regulations.