Hawaii Supreme Court February 28, 2006, 26488 (Tax Appeal of Subway Real Estate Corp. v. Director of Taxation)

Opinion of the Court by

ACOBA, J.

We hold in this appeal by Appellants Cross-Appellee Director of Taxation, State of Hawai'i (the Director) from the March 9, 2004 final judgment of the Tax Appeal Court (the court)

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that (1) the rule of strict construction of statutes does not apply in this case to Hawai'i Revised Statutes (HRS) § 237-2 (2001 Repl);

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(2) the Director’s assessment of Hawai'i