In Re the Tax Appeal of Hawaiian Flour Mills, Inc.

NAKAYAMA, Justice.

Appellant Hawaiian Flour Mills, Inc. (HFM) instituted an action in the tax appeal court contesting the assessment of general excise taxes (GET) and use taxes made by appellee State of Hawai'i Director of Taxation (Director) on the sale and use of certain food products that HFM imported into Hawaii for resale to American Hawaii Cruises (AHC), a cruise line. HFM contended that the assessments violated the Commerce Clause of the United States Constitution because sales of competing local food products were exempt from the GET, pursuant to Hawai'i Revised Statutes (HRS) §…