In re the Tax Appeal of Brewer & Co.

*241OPINION OF THE COURT BY

NAKAMURA, J.

C. Brewer & Company, Limited, a Hawaii corporation (Brewer or the taxpayer), appeals from a decision of the Tax Appeal Court sustaining the assessment of general excise taxes on the value of services it rendered on behalf of or furnished to wholly owned subsidiary corporations, and the interest on funds borrowed and disbursed on their account. The taxpayer maintains the transactions in question were not within the purview of the general excise taxes imposed by HRS § 237-13, because they entailed neither the payment of consideration by the subsidiaries nor…