In Re the Tax Appeal of Ulupalakua Ranch, Inc.

OPINION OF THE COURT BY

MARUMOTO, J.

This is an appeal by the State director of taxation from a tax appeal court judgment ordering repayment of $13,064.73, plus interest and costs, to the taxpayer, Ulu-palakua Ranch, Inc., hereafter referred to as URI. URI had previously paid the mentioned amount under protest pursuant to additional assessment of general excise tax made by the assessor of the second taxation division. The assessor made the assessment by treating the transaction whereby C. James Coberly, Jr., and his wife, Jean, obtained title to certain livestock of Ulupalakua Ranch as a sale…