Kauai Hotel, L.P. v. County of Kaua'i

KLEIN, Justice.

The question in this appeal by Kauai Hotel, L.P. (Taxpayer), is whether the Tax Appeal Court has jurisdiction under Hawaii Revised Statutes (HRS) chapter 232, “Tax Appeals” (1993),1 to hear and consider issues *259that were not expressly raised by the Taxpayer in its initial appeal to the board of review (Board).

I. BACKGROUND

At the time real property taxes were due and paid for the 1993-1994 tax year, the Taxpayer owned multiple parcels of land comprising what was formerly known as the “Westin Kauai” hotel. The tax assessor for the County of Kaua'i (County) valued the two parcels…