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ARIZONA DEPT. OF REV. v. TRANSAMERICA TITLE

No. 1 CA-CIV 3832.

124 Ariz. 428 (1979)

604 P.2d 1139

ARIZONA DEPARTMENT OF REVENUE, Appellant, v. TRANSAMERICA TITLE INSURANCE COMPANY, a California Corporation; Transamerica Title Insurance Company of Arizona, an Arizona Corporation; and Transamerica Real Estate Tax Services, a California Corporation, Appellees.

Court of Appeals of Arizona, Division 1, Department A.

Rehearing Denied April 16, 1979.

Review Granted May 1, 1979.

Attorney(s) appearing for the Case

Bruce E. Babbitt, Former Atty. Gen., John A. LaSota, Jr., Atty. Gen. by Frank L. Migray, Asst. Atty. Gen., Phoenix, for appellant.

Lewis & Roca by John P. Frank, David R. Frazer and John C. Mason, Phoenix, for appellees.

HAIRE, Judge.

The issues raised on this appeal relate to the propriety of certain federal income tax deductions taken by the appellee corporations on their state income tax returns for the years 1969 through 1972.

The appellees are subsidiaries of Transamerica Corporation within the meaning of federal income tax law. For the years in question, and for many years prior thereto, Transamerica Corporation and all of its subsidiaries (approximately 200 in number...

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