Hawaii Revised Statutes

Haw. Rev. Stat. § 232-19 (2026)

Appeals; procedure

✓ current as of July 2026

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APPEALS FROM TAX APPEAL COURT

§232-19 Appeals; procedure. Any taxpayer or county aggrieved or the assessor may appeal to the intermediate appellate court, subject to chapter 602, from the decision of the tax appeal court by filing a written notice of appeal and depositing the costs of appeal, in the manner required by court rules, within thirty days after the filing of the decision or within thirty days after entry of final judgment. The appeal shall be considered and treated for all purposes as a general appeal and shall bring up for determination all questions of fact and all questions of law, including constitutional questions, involved in the appeal. A notice of appeal may be amended at any time up to the final determination of the tax liability by the last court from which an appeal may be taken. The appellate court shall enter a judgment in conformity with its opinion or decision.

All such appeals shall be speedily disposed of and, in the hearing and disposition thereof, shall be given preference over other litigation in the discretion of the court. [L 1932 2d, c 40, §51; RL 1935, §1950; am L 1939, c 208, §12; RL 1945, §5214; RL 1955, §116-16; am L 1963, c 92, §12; HRS §232-19; am L 1973, c 51, §2; am L 2004, c 202, §20; am L 2006, c 94, §1; am L 2010, c 109, §1; am L 2025, c 10, §2]

Case Notes

Taxpayer's 42 U.S.C. §1983 claim against validity of Hawaii's general excise tax barred, where state remedies available to taxpayer were "plain, adequate, and complete". 940 F. Supp. 260 (1995).

Valuation by tax appeal court fair and just. 13 H. 125 (1900).

Scope of review. 34 H. 515 (1938).

Notice of appeal, sufficiency, amendment. 35 H. 855 (1941).

Deputy tax commissioner has right to appeal. 44 H. 584, 358 P.2d 539 (1961).

Court's determination of value can only be disturbed if clearly erroneous. 47 H. 41, 384 P.2d 287 (1963).

Findings of tax appeal court are to be sustained unless shown to be erroneous, and burden of proof is on appellant. 53 H. 45, 487 P.2d 1070 (1971).

Order vacating the challenged tax assessments and directing the city to take remedial action constituted "the decision of the tax appeal court" that finally decided the tax appeal cases and was the order appealable under this section. 109 H. 14, 122 P.3d 809 (2005).

A separately filed judgment is not required as a prerequisite to an appeal to the supreme court. 108 H. 69 (App.), 116 P.3d 711 (2005).

Notes of Decisions

Cited in 11 cases (3 in the last 5 years), 1976–2025 · leading case: Tax Appeal of Alford v. City & Cnty. of Honolulu, 122 P.3d 809 (Haw. 2005).

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Tax Appeal of Alford v. City & Cnty. of Honolulu, 122 P.3d 809 (Haw. 2005). · cites it 18× “In response, Taxpayers maintain that the July 23, 2002 order is the order that finally decided the underlying tax appeal cases and that it constitutes the “decision of the tax appeal court” that is appealable under HRS § 232-19 (1993). We believe Taxpayers are correct.”

Tax Appeal of Lewis v. Kawafuchi, 116 P.3d 711 (Haw. App. 2005). · cites it 12× “HRS § 232-19 (2001) (emphasis supplied). Thus, either taxpayer or assessor may appeal from the decision of the TAC to the supreme court [9] and the supreme court must enter a judgment only after rendering its "opinion or decision" when all appeals are done.”

In Re the Tax Appeal of Hawaiian Tel. Co., 608 P.2d 383 (Haw. 1980). · cites it 2× “Taxpayer, Hawaiian Telephone Company, appeals from the Tax Appeal Court’s findings of fact and conclusions of law and judgment in favor of the Director of Taxation entered on January 28, 1975, pursuant to HRS § 232-19 (1976). After careful consideration of all questions…”

In re Tax Appeal of Travelocity.Com., L.P. v. Dir. of Taxation., 346 P.3d 157 (Haw. 2015). · cites it 2× “See HRS § 232-19(b)(2)(B). 41 . The tax court did not make findings of fact or conclusions of law, pursuant to Hawai'i Rules of Civil Procedure (HRCP) Rule 52(a).”

Moore v. Kamikawa, 940 F. Supp. 260 (D. Haw. 1995). · cites it 2× “Haw.Rev.Stat. § 232-19 (1992). The state remedies available to Plaintiff thus bar him from presently seeking review of his general excise tax assessment in federal court.”

In Re: West Maui Resort Partners LP v. Cnty. of Maui. Consol. with SCAP-23-0000139., 154 Haw. 121 (Haw. 2024). · cites it 4× “HRS § 232-19 (2017) provides the procedure for appeals from the Tax Appeal Court and states: Any taxpayer or county aggrieved or the assessor may appeal to the intermediate appellate court, subject to chapter 602, from the decision of the tax appeal court by filing a written…”

Suganuma v. Goodman, 556 P.3d 1281 (Haw. App. 2024). · cites it 4× “Appeals from the Tax Appeal Court are taken under HRS § 232-19 from "the decision of the tax appeal court .”

In re: Tax Appeal of Hawaiian Airlines, Inc. v. Dep't of Taxation (Haw. App. 2025). · cites it 4× “HRS § 232-19 (2017), amended by, 2025 Haw.”

Ocean Resort Villas Vacation Owners Ass'n v. Cnty. of Maui. Petition for Writ of Mandamus, filed 08/10/2018. (Haw. 2020). · cites it 2× “Appeals of TAC decisions go to the ICA (HRS § 232-19), then on to this court (HRS § 602-59), for further review of any constitutional rulings.”

Travelocity.Com LP v. Chang (Haw. 2013). · cites it 2× “2d 334, 338-39 (1999); (3) such writs are not meant to serve as legal remedies in lieu of normal appellate procedures; and (4) HRS § 232-19 (Supp. 2012) sets forth the procedure for appeals from the tax appeal court.”

In re the Tax Appeal of Amco Elec. Co., 554 P.2d 238 (Haw. 1976). · cites it 2× “Pursuant to HRS § 232-19 (Supp. 1975), Amco Electric Company (hereinafter referred to as taxpayer) has appealed from a judgment by the tax appeal court which upheld the disallowance by the director of taxation of an exemption from the general excise tax claimed by the taxpayer.”

— Haw. Rev. Stat. § 232-19(b)(2)(B) — 1 case

In re Tax Appeal of Travelocity.Com., L.P. v. Dir. of Taxation., 346 P.3d 157 (Haw. 2015). “See HRS § 232-19(b)(2)(B). 41 . The tax court did not make findings of fact or conclusions of law, pursuant to Hawai'i Rules of Civil Procedure (HRCP) Rule 52(a).”

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