RICHARDSON, Chief Justice.
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...
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