HAR § 18-231-19.5-14 — Narrow construction of section

The disclosure provided by section 231-19.5, HRS, is a narrow exception to the well-established principle that tax return information, which includes written opinions, is confidential. The purpose of section 231-19.5, HRS, is to enhance correct reporting by issuing guidance to taxpayers in areas where the interpretation of the tax laws is unclear, and is not to open to public inspection the voluminous routine correspondence to taxpayers concerning well-established interpretations or principles of tax law. To protect the integrity of the tax system which depends upon voluntary compliance and reporting, any doubts about whether information should be publicly disclosed shall be resolved in favor of nondisclosure.