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Hawaii Revised Statutes

Haw. Rev. Stat. § 232-1 (2026)

  Appeals by persons under contractual obligations

✓ current as of July 2026
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     §232-1  Appeals by persons under contractual obligations.  Whenever any person is under a contractual obligation to pay a tax assessed against another, the person shall have the same rights of appeal to the taxation board of review, the tax appeal court, and the intermediate appellate court, subject to chapter 602, in the person's own name, as if the tax were assessed against the person.  The person against whom the tax is assessed shall also have a right to appear and be heard on any such application or appeal. [L 1932 2d, c 40, §55; RL 1935, §1936; RL 1945, §5201; RL 1955, §116-1; HRS §232-1; gen ch 1985; am L 2004, c 202, §18; am L 2006, c 94, §1; am L 2010, c 109, §1; am L 2021, c 118, §2]

 

Case Notes

 

  When lessee may properly appeal.  33 H. 214 (1934).

  A party with a secondary contractual obligation to pay the tax assessed against another has a right under this section to challenge that assessment to the tax appeal court.  85 H. 36, 936 P.2d 672 (1997).

  A person under a contractual obligation to pay property taxes need not pay the taxes in order to perfect an appeal of the tax assessment.  85 H. 36, 936 P.2d 672 (1997).

 

 

Notes of Decisions
Cited in 5 cases (3 in the last 5 years), 1997–2025 · leading case: In Re of the Tax Appeal of Maile Sky Court Co. v. City & Cnty. of Honolulu, 936 P.2d 672 (Haw. 1997).
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In Re of the Tax Appeal of Maile Sky Court Co. v. City & Cnty. of Honolulu, 936 P.2d 672 (Haw. 1997). · cites it 30× “Pursuant to HRS § 232-1, MSC, as the person under a contractual obligation to pay the tax assessed against another, has the same rights of appeal as if the tax were assessed against it.”
Tax Appeal of Univ. of Hawai'i v. City & Cnty. of Honolulu, 77 P.3d 478 (Haw. 2003). · cites it 4× “This court ultimately held that MSC did have standing under HRS § 232-1 as a party having a contractual obligation to pay the real property taxes on behalf of the lessees.”
In Re: Tax Appeal of Hawaiian Airlines, Inc. v. Dep't of Taxation. ICA s.d.o., filed 03/15/2024 [ada], 154 Haw. 48. Motion for Reconsideration, filed 03/25/2024. ICA Order Denying Motion for Reconsideration, filed 04/01/2024 [ada]. Application for Writ of Certiorari, filed 05/13/2024. S.Ct. Order Accepting Application for Writ of Certiorari, filed 07/08/2024 [ada]. (Haw. 2024). · cites it 5× “Hawaiian indicated it succeeded to Boeing’s appeal rights as the party contractually required to pay a portion of Boeing’s assessed taxes pursuant to HRS § 232-1 (2017).7 On June 25, 2021, a “Notice of Corrected Proposed Assessment of General Excise and/or Use Tax for the…”
In Re: Tax Appeal of Hawaiian Airlines, Inc., 544 P.3d 712 (Haw. App. 2024). · cites it 4× “The notice instructed Boeing to submit payment immediately if it agreed 3 Hawaiian maintained it had "the right, under [HRS § 232-1 (2017)] to any appeal rights Boeing may have to challenge the tax imposed.”
In re: Tax Appeal of Hawaiian Airlines, Inc. v. Dep't of Taxation (Haw. App. 2025). · cites it 4× “2 HRS § 232-1 (2017) gives a person contractually obligated to pay a tax assessed against another the right of appeal "as if the tax were assessed against the person.”
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