In Re the Tax Appeal of Hawaiian Land Co.

*46OPINION OF THE COURT BY

ABE, J.

As of January 1, 1963 the Assessor valued and assessed Ala Moana Center as follows.

Building $ 7,321,300

Land 9,732,800

$17,054,100

*47On the other hand, Hawaiian Land Company, Ltd. (“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 be lowered under provisions of HRS § 232-3 (1968).1 Forthwith the Board determined the proper assessment to be:

Building $ 9,357,600

La…