Hawaii Supreme Court September 24, 1982, NO. 8203 (In re the Tax Appeal of E-Z Serve, Inc.)

Per Curiam.

This is an appeal from a judgment of the tax appeal court, holding appellant liable as a wholesaler of gasoline. We affirm.

*284Appellant is a foreign corporation with no place of business, officers, or activities in the State of Hawaii other than those involved in the transactions in question. Appellant refines and owns gasoline on the Mainland of the United States.