Haw. Rev. Stat. » Haw. Rev. Stat. / Chapter 232
Hawaii Revised Statutes

Haw. Rev. Stat. § 232-2 (2025)

  Assessment in accordance with return no cause of grievance

✓ laws through the 2025 session: the 2026 session is not included
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     §232-2  Assessment in accordance with return no cause of grievance.  No taxpayer shall be deemed aggrieved by an assessment to the extent that it is in accordance with the taxpayer's return. [L 1939, c 208, pt of §5; RL 1945, pt of §5211; RL 1955, §116-2; HRS §232-2; gen ch 1985]

 

Cross References

 

  Not applicable to monthly returns, see §237-30.

 

Case Notes

 

 

  Inapplicable where director of taxation changes assessment classification to one taxed at higher rate.  63 H. 579, 633 P.2d 535 (1981).

 

 

Notes of Decisions
Cited in 3 cases, 1977–1999 · leading case: In re the Tax Appeal of Otis Elevator Co., 566 P.2d 1091 (Haw. 1977).
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In re the Tax Appeal of Otis Elevator Co., 566 P.2d 1091 (Haw. 1977). · cites it 2× “Should the in-state taxpayer described in any part of Question #1 be classified for taxation under HRS § 232-2 as a manufacturer who does not sell the product and therefore is subject to tax under HRS § 238-2(3)?”
Tax Appeal of Grace Bus. Dev. Corp. v. Kamikawa, 994 P.2d 591 (Haw. App. 1999). · cites it 2× “Finally, the State argues that HRS § 232-2 (Supp.1998), which states that “[n]o taxpayer shall be deemed aggrieved by an assessment to the extent that it is in accordance with the taxpayer’s return,” precludes relief because, by definition in this case of payment under protest,…”
In re the Tax Appeal of Photo Mgmt., Inc., 633 P.2d 535 (Haw. 1981). · cites it 2× “Accordingly, because (1) PMI mass produces photos with photographers who are not highly skilled, (2) the substance of the transaction between PMI and the various photo retailers is the print itself, and (3) the photo retailers purchase the prints from PMI for purposes of resale…”
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