In re the Tax Appeal of Alexander & Baldwin, Inc.

OPINION OF THE COURT BY

LEVINSON, J.

During the tax. years 1963 through 1967, the business *451activities of A & B Commercial Company, a division of Alexander & Baldwin, Inc. and the taxpayer herein, included 1) the sale of radio, television and refrigeration appliance parts to licensed repairmen, 2) the sale of imported appliance parts directly to consumers in conjunction with repair work performed by the taxpayer, and 3) the sale of paint to licensed taxpayers in the automobile painting business. The taxpayer originally reported receipts from sales of parts to its customers in the appliance…