HOLOHAN, Justice (Retired).
The trial court granted a summary judgment for the Arizona Department of Revenue ("Department") in an action brought by Walter E. Heller Western, Inc. ("Heller Western") challenging the Department's assessment of its income tax liability for the years 1976, 1977, 1978, and 1979. The Court of Appeals reversed, and the Department petitioned this court for review. The dispute between the Department and Heller Western, a multistate commercial...
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