In Re the Tax Appeal of Central Union Church

OPINION OF THE COURT BY

NAKAMURA, J.

The issue in this taxpayer appeal from the Tax Appeal Court is whether certain sums derived from the operation of a retirement home by a church are subject to taxation under HRS Chapter 237, the general excise tax statute. Finding the receipts in question are exempt from taxation thereunder, we reverse the Tax Appeal Court’s decision and order.

The taxpayer, Central Union Church — Arcadia Retirement Residence (hereafter Arcadia), filed a general excise tax return for the month of January, 1977, claiming exemptions from taxation for entrance fees, monthly…