Decisions
These decisions come from the Arizona Department of Revenue Hearing Office and the Director’s Office and are posted here as required by A.R.S. § 42-2077
| Document Type | Category | Document ID | Description | Tags | Decision Date |
|---|---|---|---|---|---|
| Decisions | Corporate Tax | 201800182-C |
Combined reporting of overall net income by parent company and its unitary affiliates was necessary where parent designed and developed programs for implementation by its affiliates and directed the affiliates' day-to-day operations. |
Hearing | 05/05/2020 |
| Decisions | Corporate Tax | 200800188-C |
Sourcing of slot machine owner’s receipts for sales factor purposes. Whether placing machines in casinos was rental of personal property. |
Hearing | 02/11/2020 |
| Decisions | Corporate Tax | 201200235-C |
Gross receipts from Taxpayer’s sale of its assets should be excluded from the sales factor. |
Hearing | 05/31/2013 |
| Decisions | Corporate Tax | 201100309-C |
Taxpayer did not use its investment account in its regular trade or business so its investment income was not business income. Reimbursement of shared business expenses from a co-tenant was business income. |
Hearing | 07/30/2012 |
| Decisions | Corporate Tax | 200900134-C |
To claim an enterprise zone credit the taxpayer must be the employer. |
Director | 05/24/2011 |
| Decisions | Corporate Tax | 200800192-C |
Calculation of the enterprise zone credit amount |
Hearing | 10/16/2009 |
| Decisions | Corporate Tax | 200800128-C |
Gain from a §338(h)(10) sale of a subsidiary should be treated as business income |
Hearing | 07/10/2009 |
| Decisions | Corporate Tax | 200700189‑C |
Taxpayer not allowed research and development credit, under A.R.S. 43-1168, where the Taxpayer relies on unsubstantiated estimates of research expenditures from an acquired company in years preceding the acquisition of such company to calculate the credit. |
Director | 02/09/2009 |
| Decisions | Corporate Tax | 200700189-C |
Tax credit study was not based on sufficient evidence to prove entitlement to an increased research and development credit. |
Director | 02/06/2009 |
| Decisions | Corporate Tax | 200600091-C |
Gain from the sale of stock in a foreign subsidiary owned by a holding company was apportionable business income. |
Director | 09/08/2008 |
| Decisions | Corporate Tax | 200600091-C |
Gain from the sale of stock in a foreign subsidiary owned by a holding company was apportionable business income. |
Director | 09/08/2008 |
| Decisions | Corporate Tax | 200700083-C |
Whether Arizona has sufficient nexus to tax income from an out-of-state franchisor that receives license and royalty fees from Arizona franchisees. |
Hearing | 03/27/2008 |
| Decisions | Corporate Tax | 200600161-C |
Net operating loss carryforward and continuity of business enterprise; municipal bond interest. |
Director | 10/29/2007 |
| Decisions | Corporate Tax | 200600082-C |
Are gains arising from certain transactions business or nonbusiness income? |
Hearing | 06/15/2007 |
| Decisions | Corporate Tax | 200600161-C |
In calculating Arizona net operating loss carryforward in a merger; Is the exclusion of in-state municipal bonds, unconstitutional? |
Hearing | 06/07/2007 |
| Decisions | Corporate Tax | 200600091-C |
Do gains arising from sales of common stock of a majority -owned overseas subsidiary constitute busness income apportionable to Arizona? |
Director | 05/14/2007 |
| Decisions | Corporate Tax | 200600105-C |
Effect of prior closing agreement concerning use of the completed contract method of accounting and an apportionment method for completed contracts. |
Hearing | 03/07/2007 |
| Decisions | Corporate Tax | 200500075-C |
Does the construction of storm water retention areas and sewer systems qualify for credit as pollution control equipment. |
Director | 02/12/2007 |
| Decisions | Corporate Tax | 200500147-C |
Does the construction of storm water retention areas and sewer systems qualify for credit as pollution control equipment. |
Director | 01/26/2007 |
| Decisions | Corporate Tax | 200600088-C |
Whether a merger termination fee is business or non-business income; A.R.S. 42-2076 |
Hearing | 10/10/2006 |
| Decisions | Corporate Tax | 200600035-C |
REIT dividend deduction not allowed where the corporate REIT and beneficiary are part of the same unitary group |
Hearing | 09/15/2006 |
| Decisions | Corporate Tax | 200400017-C |
Arizona consolidated group was required to include in the numerator of the Arizona sales factor a portion of the sales made by a partnership, in which some members of the group had an interest, to another member of the group doing business in Arizona. |
Director | 12/09/2004 |
| Decisions | Individual Income Tax | 202100028-I |
Automatic stay after taxpayer's bankruptcy petition did not apply. The issuance of assessments is not an action to collect a debt against either the debtor taxpayer or a bankruptcy estate, but rather an act to determine liability. |
Hearing | 01/27/2022 |
| Decisions | Individual Income Tax | 202100029-I |
Taxes in assessments issued in 2019 were not subject to a bankruptcy discharge order where the taxpayer had filed the bankruptcy petition in 2016. The issuance of assessments is not an action to collect a debt, but rather an act to determine liability. Whether some or part of the tax assessed is affected by a bankruptcy filing is a different question from whether the issuance of an assessment is valid. |
Hearing | 01/27/2022 |
| Decisions | Individual Income Tax | 202100037-I |
A.R.S. § 43-1071(F) did not create new and otherwise unavailable credit for taxes paid to California where group return filed in California had forfeited California credit for taxes paid in Arizona. |
Hearing | 12/14/2021 |