Compusa Stores, LP v. Department of Taxation, State of Hawaii.

Opinion of the Court by

RECKTENWALD, C.J.

This case arises out of the assessment of the Hawaii use tax by the State of Hawaii, Department of Taxation (Department) against CompUSA Stores L.P. (CompUSA) on goods that were transported from the mainland to CompUSA’s retail stores in Hawaii during the period between July 1, 1999 and December 31, 2002. During that period, CompUSA caused consumer electronics goods from various mainland vendors to be shipped to Hawaii in order to restock Com-pUSA’s retail stores in this state.

Hawaii Revised Statutes (HRS) § 238-2 (1993), quoted infra, governs the…