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Hawaii Revised Statutes

Haw. Rev. Stat. § 232-3 (2026)

  Grounds of appeal, real property taxes

✓ current as of July 2026
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     §232-3  Grounds of appeal, real property taxes.  In the case of a real property tax appeal, no taxpayer or county shall be deemed aggrieved by an assessment, nor shall an assessment be lowered or an exemption allowed, unless there is shown:

     (1)  Assessment of the property exceeds by more than twenty per cent the ratio of assessment to market value used by the director of taxation as the real property tax base;

     (2)  Lack of uniformity or inequality, brought about by illegality of the methods used or error in the application of the methods to the property involved;

     (3)  Denial of an exemption to which the taxpayer is entitled and for which the taxpayer has qualified; or

     (4)  Illegality, on any ground arising under the Constitution or laws of the United States or the laws of the State (in addition to the ground of illegality of the methods used, mentioned in paragraph (2)). [L Sp 1957, c 1, §13(a); am L 1963, c 92, §2; Supp, §116-2.1; HRS §232-3; am L 1973, c 115, §1; gen ch 1985; am L 2017, c 12, §37]

 

Law Journals and Reviews

 

  Real Property Tax Litigation in Hawaii.  III HBJ, no. 13, at 57 (1999).

 

Case Notes

 

  Method of valuation of cane lands inappropriate and illegal.  47 H. 41, 384 P.2d 287 (1963).

  "Assessment" means the percentage of fair market value, and unless this valuation exceeds the full market value there can be no reduction.  53 H. 45, 487 P.2d 1070 (1971).

  Merely showing discrepancies in assessment of different parcels of land is not sufficient to prove denial of equal protection.  53 H. 45, 487 P.2d 1070 (1971).

  Without appellant providing evidence of fair market value of the fee simple interest in the land, an appeal showing method used in determining assessment was wrong cannot be sustained.  60 H. 487, 591 P.2d 607 (1979).

 

 

Notes of Decisions
Cited in 10 cases (1 in the last 5 years), 1971–2025 · leading case: In Re the Tax Appeal of Hawaiian Land Co., 487 P.2d 1070 (Haw. 1971).
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In Re the Tax Appeal of Hawaiian Land Co., 487 P.2d 1070 (Haw. 1971). · cites it 106× “("Taxpayer") claimed the following values were applicable to Ala Moana as of the same date: Building $ 6,930,000 Land 7,274,000 ___________ $14,204,000 Thus, Taxpayer appealed to the Board of Review alleging the Assessor committed numerous errors that would allow assessment to…”
Alvarez Fam. Trust v. Ass'n of Apt. Owners of the Kaanapali Alii, 221 P.3d 452 (Haw. 2009). · cites it 7× “, review was appropriate because the facts were fully developed, and the appellate analysis would only involve application of HRS § 232-3(1) to the findings that had already been made.”
Corboy v. Louie., 283 P.3d 695 (Haw. 2011). · cites it 7× “16 HRS § 232-3 (2001), concerning tax appeals provides: Grounds of appeal, real property taxes.”
In Re of the Tax Appeal of Maile Sky Court Co. v. City & Cnty. of Honolulu, 936 P.2d 672 (Haw. 1997). · cites it 4× “HRS § 232-3 provides in pertinent part: Grounds of appeal, real property taxes.”
Tax Appeal of Cnty. of Maui v. KM HAW., 915 P.2d 1349 (Haw. 1996). · cites it 6× “HRS § 232-3 provides in pertinent part: Grounds of appeal, real property taxes.”
Tax Appeal of Hawaii Prince Hotel Waikiki Corp. v. City & Cnty. of Honolulu, 974 P.2d 21 (Haw. 1999). · cites it 4× “HRS § 232-3 provides in relevant part: Grounds of appeal, real property taxes.”
In Re the Tax Appeals of Amfac, Inc., 654 P.2d 363 (Haw. 1982). · cites it 4× “In this regard, HRS § 232-3(2) (1976) provides that no assessment shall be lowered on appeal unless there is shown: (2) Lack of uniformity or inequality, brought about by illegality of the methods used or error in the application of the methods to the property involved,.”
Kauai Hotel, L.P. v. Cnty. of Kaua'i, 915 P.2d 1358 (Haw. 1996). · cites it 6× “HRS § 232-3 provides in pertinent part: Grounds of appeal, real property taxes.”
Piezko v. Cnty. of Maui (Haw. 2025). · cites it 12× “HRS § 232-3 (2017). To effectuate this appeals process, taxpayers “may appeal directly to the tax appeal court,” but only if the taxpayers “first obtain a decision from an administrative body established by county ordinance[] .”
Ocean Resort Villas Vacation Owners Ass'n v. Cnty. of Maui. Petition for Writ of Mandamus, filed 08/10/2018. (Haw. 2020). · cites it 8× “” HRS § 232-3 is titled “Grounds for appeal, real property taxes,” and it states that a taxpayer aggrieved by an assessment must show a “[l]ack of uniformity or inequality, brought about by illegality of the methods used or error in the application of the methods to the property…”
— Haw. Rev. Stat. § 232-3(1) — 4 cases
In Re the Tax Appeal of Hawaiian Land Co., 487 P.2d 1070 (Haw. 1971). “("Taxpayer") claimed the following values were applicable to Ala Moana as of the same date: Building $ 6,930,000 Land 7,274,000 ___________ $14,204,000 Thus, Taxpayer appealed to the Board of Review alleging the Assessor committed numerous errors that would allow assessment to…”
Alvarez Fam. Trust v. Ass'n of Apt. Owners of the Kaanapali Alii, 221 P.3d 452 (Haw. 2009). “, review was appropriate because the facts were fully developed, and the appellate analysis would only involve application of HRS § 232-3(1) to the findings that had already been made.”
Tax Appeal of Cnty. of Maui v. KM HAW., 915 P.2d 1349 (Haw. 1996). “HRS § 232-3 provides in pertinent part: Grounds of appeal, real property taxes.”
Kauai Hotel, L.P. v. Cnty. of Kaua'i, 915 P.2d 1358 (Haw. 1996). “HRS § 232-3 provides in pertinent part: Grounds of appeal, real property taxes.”
— Haw. Rev. Stat. § 232-3(2) — 4 cases
In Re of the Tax Appeal of Maile Sky Court Co. v. City & Cnty. of Honolulu, 936 P.2d 672 (Haw. 1997). “HRS § 232-3 provides in pertinent part: Grounds of appeal, real property taxes.”
In Re the Tax Appeals of Amfac, Inc., 654 P.2d 363 (Haw. 1982). “In this regard, HRS § 232-3(2) (1976) provides that no assessment shall be lowered on appeal unless there is shown: (2) Lack of uniformity or inequality, brought about by illegality of the methods used or error in the application of the methods to the property involved,.”
Tax Appeal of Hawaii Prince Hotel Waikiki Corp. v. City & Cnty. of Honolulu, 974 P.2d 21 (Haw. 1999). “HRS § 232-3 provides in relevant part: Grounds of appeal, real property taxes.”
Ocean Resort Villas Vacation Owners Ass'n v. Cnty. of Maui. Petition for Writ of Mandamus, filed 08/10/2018. (Haw. 2020). “” HRS § 232-3 is titled “Grounds for appeal, real property taxes,” and it states that a taxpayer aggrieved by an assessment must show a “[l]ack of uniformity or inequality, brought about by illegality of the methods used or error in the application of the methods to the property…”
— Haw. Rev. Stat. § 232-3(4) — 1 case
Ocean Resort Villas Vacation Owners Ass'n v. Cnty. of Maui. Petition for Writ of Mandamus, filed 08/10/2018. (Haw. 2020). “” HRS § 232-3 is titled “Grounds for appeal, real property taxes,” and it states that a taxpayer aggrieved by an assessment must show a “[l]ack of uniformity or inequality, brought about by illegality of the methods used or error in the application of the methods to the property…”
— Haw. Rev. Stat. § 232-3(i) — 1 case
In Re the Tax Appeal of Hawaiian Land Co., 487 P.2d 1070 (Haw. 1971). “("Taxpayer") claimed the following values were applicable to Ala Moana as of the same date: Building $ 6,930,000 Land 7,274,000 ___________ $14,204,000 Thus, Taxpayer appealed to the Board of Review alleging the Assessor committed numerous errors that would allow assessment to…”
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