In Re the Tax Appeal of Fasi

OPINION OF THE COURT BY

RICHARDSON, C.J.

This appeal seeks to determine whether a service contract between APCOA, ITT (APCOA) and the State of Hawaii under which APCOA operates the airport parking facilities located on State-owned land at Honolulu International Airport meets the requirements of HRS § 246-36 (1976) for exempting APCOA from real property tax liability. Appellant State of Hawaii contends that the tax appeal court was without jurisdiction to consider the issue with respect to tax years 1972 through 1976 because appellee Mayor, City & County of Honolulu, filed an untimely appeal to…