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IN RE FUJI PHOTO FILM HAWAII, INC.

No. 17264.

904 P.2d 517 (1995)

79 Hawai`i 503

In re TAX APPEAL OF FUJI PHOTO FILM HAWAII, INC., Taxpayer-Appellee.

Supreme Court of Hawai`i.

October 9, 1995.

Attorney(s) appearing for the Case

Gary S. Ige, Deputy Attorney General, Honolulu, for Director of Taxation/appellant.

Kenneth G.K. Hoo (Calvert G. Chipchase, Eric T. Kawatani, and Peter J. Hamasaki with him on the brief of McCorriston Miho Miller Mukai), Honolulu, and Philip M. Moilanen, pro hac vice, of Bullen, Moilanen, Klaassen & Swan, P.C., Jackson, MI, for Fuji Photo Film Hawaii, Inc./appellee.

Before MOON, C.J., and KLEIN, LEVINSON, NAKAYAMA and RAMIL, JJ.

KLEIN, Justice.

The question in this appeal by the Department of Taxation from the Tax Appeal Court is whether the "photoprocessing" activities of Fuji Photo Film Hawaii, Inc. (Fuji) constitute "manufacturing," which is taxable at the rate of one-half of one percent, or a "service," which is taxable at the rate of four percent. We agree with the Tax Appeal Court's conclusion that the Director of Taxation's (Tax Director)...

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