KIDWELL, Justice.
This is an appeal from the findings of fact, conclusions of law and judgment of the tax appeal court, which determined that gross income from sales made in 1972 of new motor vehicles by the taxpayer to U-Drive car rental operators was subject to general excise taxation at the retail rate of 4% rather than at the wholesale rate of ½ of 1%. The appeal presents a question of interpretation of HRS § 237-4, as amended, which provides in pertinent...
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