Tax Appeal of Subway Real Estate Corp. v. Director of Taxation

Opinion of the Court by

ACOBA, J.

We hold in this appeal by Appellants Cross-Appellee Director of Taxation, State of Hawai'i (the Director) from the March 9, 2004 final judgment of the Tax Appeal Court (the court) 1 that (1) the rule of strict construction of statutes does not apply in this case to Hawai'i Revised Statutes (HRS) § 237-2 (2001 Repl); 2 (2) the Director’s assessment of Hawai'i general excise taxes (GET) on the subleasing activities of Taxpayer-Appellee-Cross Appellant Subway Real Estate Corp. (Taxpayer) was proper inasmuch as (a) Taxpayer gained or economically benefitted under…