MENOR, Justice.
The appellant, Director of Taxation for the State of Hawaii [hereinafter the State], appeals from a final judgment and order of the Tax Appeal Court in favor of Valley of the Temples Corporation [hereinafter the Taxpayer].
The facts relevant to this appeal are as follows: The State assessed the Taxpayer's land and improvements thereon at a value of $1,996,348.00 for the real property tax year 1972-1973, following normal assessment procedures...
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