OPINION OF THE COURT BY STAINBACK, J.
This case involves cross appeals from the tax appeal court. The evidentiary facts in the case are not in dispute, the major portions appearing in a stipulation of facts filed by the parties and in several exhibits.
The taxpayer, Gay & Robinson, a copartnership, owns lands at Makaweli, Kauai; its business is agricultural, primarily the raising of sugar cane which formerly had been processed into raw sugar by Hawaiian...
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