In re the Tax Appeal of Photo Management, Inc.

*580OPINION OF THE COURT BY

RICHARDSON, C J.

The issue on appeal is whether the taxpayer, Photo Management, Inc. (hereafter PMI) should be assessed at the lower excise tax rate of one-half of one percent or at the higher rate of four percent. The Tax Appeal Court ruled that the appropriate tax classification for MPI’s photographing business was “wholesaling,” taxable at the lower rate, rather than “service business or calling,” taxable at the higher rate. After close review of the record, we affirm.

I

PMI was incorporated in Hawaii in December of 1974 for the purpose of taking, processing and selling…