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SPIRENT HOLDING v. STATE, DEPT. OF TAX.

No. 29199.

216 P.3d 1243 (2009)

In the Matter of the Tax Appeal of SPIRENT HOLDING CORP. & Subsidiaries, Taxpayer Appellant-Appellee, v. STATE of Hawai`i, DEPARTMENT OF TAXATION, Appellee-Appellant.

Intermediate Court of Appeals of Hawai`i.

July 14, 2009.

Attorney(s) appearing for the Case

Hugh R. Jones and Damien A. Elefante, Deputy Attorneys General, State of Hawai`i, on the briefs, for Appellee-Appellant.

Ronald I. Heller (Torkildson Katz Moore Hetherington & Harris), Honolulu, on the briefs, for Taxpayer Appellant-Appellee.

WATANABE, Acting C.J., FUJISE, and LEONARD, JJ.

Opinion of the Court by WATANABE, Acting C.J.

In this appeal, the Director of Taxation, State of Hawai`i (Director or State) challenges the final judgment entered by the Tax Appeal Court of the State of Hawai`i (tax appeal court)1 on July 14, 2008 (final judgment) and two orders entered by the tax appeal court on March 7, 2008 (collectively, summary judgment orders), the first of which denied the Director's December 11, 2007 motion for...

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