OPINION
OGG, Presiding Judge.
This is an appeal taken by the appellant-defendant, State of Arizona, Department of Revenue (Department), from the trial court's order granting summary judgment in a declaratory judgment action to the plaintiff-appellee, Knoell Brothers Construction, Inc. (Knoell).
In this appeal, this court must determine the proper method to be used by the Department in calculating Knoell's liability under the transaction privilege tax...
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