Opinion of the Court by MOON, C.J.
We granted the application of the petitioner-appellee Ray K. Kamikawa, Director of Taxation, State of Hawai`i [hereinafter, the Director] for a writ of certiorari on December 9, 1999 to review the decision of the Intermediate Court of Appeals (ICA). See Grace Business Dev. Corp. v. Kamikawa,
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