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The Director of Finance of D is responsible for the valuation and assessment of property for the purposes of real property taxation. ROH § 8-7.1(a) provides that: The Director of Finance shall cause the fair market value of all taxable real property to be determined and annually assessed by the market data and cost approaches to value using appropriate systematic methods suitable for mass valuation of properties for taxation purposes, so selected and applied to obtain, as far as possible, uniform and equalized assessments throughout the county... The ultimate purpose of valuation is to arrive at a fair and realistic value of the property involved. Our statutory scheme of real property taxation adopts this principle by identifying `fair market value' as the relevant measure of the value of property. Market value is `the value in money of any property for which that property would sell on the open market by a willing seller to a willing buyer. The Department of Finance has adopted two basic methods of land valuation, the market data approach and the income approach (used for income-generating properties). The market data approach involves obtaining all available sales data, qualifying these as being transacted at `arms-length' conditions or being `bona fide' transactions, and comparing these recently sold properties to the one being appraised, making adjustments as necessary for comparisons. Unit prices demonstrated by actual sales, either adjusted or unadjusted, provide valid estimates of market value. Adjustments for dissimilarities in the market data approach to value are made by plus or minus dollar amount or percentages, from the comparable parcels to the subject, benchmark, or typical parcel in the neighborhood. The major factors which should be considered in the adjustments include the time of sale, terms of sale, location of compared parcels, differences in physical characteristics among them, and all other factors which might have been significant so as to influence the prices paid for the properties. Assessors are to consider three general factors affecting the value of urban and suburban residential lands: location, neighborhood characteristics, and site characteristics. Site characteristics include: (1) size and shape of lot; (2) topography and soil conditions; (3) landscaping; and (4) accessibility. In assessing shoreline properties, the 'most important factor of value' is the quality of the shoreline itself. D's tax appraiser of P's property established (1) a 'typical' lot size and (2) a 'benchmark' value, in dollars per square foot, for the particular neighborhood or area. The benchmark value was calculated by reviewing the sales data for ocean-front property in the surrounding areas from the year before last (e.g., 1986 sales data for the 1988 tax year). D assessed the property based on a typical lot size of 20,000 sq. ft. The assessor, Irene Nakamura, applied the Black Point benchmark to 20,000 sq. ft. and 50% of the benchmark to the remaining 26,707 sq. ft. The benchmark value, based on comparable sales data, was $75 per sq. ft. for 1988 and $95 per sq. ft. for 1989 in the Black Point area. D's 1988 benchmark relied heavily on the 1986 sales of three Black Point properties, which it considered comparable to P's property. These properties were calculated to have land values of $83.66, $110.27 and $82.56 per sq. ft. D also considered sales of oceanfront properties in the Diamond Head and Kahala areas that ranged from $81.08 to $155.53 per sq. ft. D determined that the benchmark should be $75 per sq. ft. for the Black Point area. The Black Point benchmark reflected a discount for the topography in the Black Point area. D made no other adjustments to the valuation of the Steiner property based on its topography. The 1989 Black Point benchmark of $95 per sq. ft. was based on 1987 sales in the surrounding areas, including the sale of one Black Point property. A careful review of the record only reveals evidence that: (1) the Steiner property and the adjoining two parcels had large areas of rocky unusable land; (2) these three parcels were previously subject to a three part valuation, 100% of benchmark for 10,000 sq. ft., 50% for 1,000 to 1,780 sq. ft., and 25% for the remaining area (roughly 25,000 to 35,000 sq. ft.);(3) three other ocean-front Black Point properties were previously subject to a two part valuation, 100% of benchmark for 10,000 sq. ft. and 50% for the balance no evidence was presented as to the topography of these parcels; (4) several Kahala Beach properties (thirteen) were subject to variable formulas in the past some were assessed at 100% of benchmark for the first 10,000 sq. ft. with the balance at 50%, for others a three part valuation was used; however, the latter properties had been assessed at 100% of benchmark for 10,000 sq. ft. and 50% for an average of 26,000 sq. ft. (range 10,000 to 40,000 sq. ft.) with relatively small remaining areas valued at 25% (average of 6,500 sq. ft., range 1,800 to 14,000 sq. ft.); (5) no specific evidence was presented as to the topography of the individual Kahala Beach properties, but the City assessor testified that (at least) some of them were level and had beach access and, no distinction was made in valuing the overage of these lots as compared to those at Black Point.

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