Aetna Life Insurance v. Park

*116OPINION OF THE COURT BY

BURNS, C. J.

Nineteen insurance companies (Companies), “foreign insurers” under Hawaii Revised Statutes (HRS) § 431-81(b), appeal from a decision rendered by the circuit court. That decision dismissed Companies’ appeal from the Insurance Commissioner’s (Commissioner) dismissal of their petition for a refund of taxes. We affirm.

On June 18, 1982 Companies petitioned the Commissioner (Docket No. 82-4, Department of Commerce and Consumer Affairs, Insurance Division) for the following orders:

1. Declaring that the provisions of HRS § 431-318,1 which impose higher tax rates on…