In re the Tax Appeal of Amco Electric Co.

OPINION OF THE COURT BY

OGATA, J.

Pursuant to HRS § 232-19 (Supp. 1975), Amco Electric Company (hereinafter referred to as taxpayer) has appealed from a judgment by the tax appeal court which upheld the disallowance by the director of taxation of an exemption from the general excise tax claimed by the taxpayer. We affirm.

A stipulation of facts was filed in the tax appeal court. Since the issue presented to us is primarily the proper construction of HRS § 237-26, rather than its application, only a brief synopsis of fa^s need be recited. In 1969, the taxpayer, a California specialty electrical…