In Re the Tax Appeal of the Queen's Medical Center

OPINION OF THE COURT BY

NAKAMURA, J.

The Tax Appeal Court declared the gross income from the operation of an office building and an adjoining parking lot by The Queen’s Medical Center (Queen’s or the taxpayer) exempt from the tax imposed by HRS § 237-13(10) 1 because it found “the primary purpose of the taxpayer’s activities in the Physicians Office Building and parking facility was to furnish better, more efficient and cost effective, complete medical care to patients, and not to produce income.” We reverse the court’s ruling because the exemption from excise taxation expressly provided for…