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DEPT. OF REV. v. GEN. MOTORS ACCEPTANCE

No. 1 CA-TX 95-0004.

188 Ariz. 441 (1996)

937 P.2d 363

ARIZONA DEPARTMENT OF REVENUE, an agency of the State of Arizona, Plaintiff-Appellee, v. GENERAL MOTORS ACCEPTANCE CORPORATION, a New York corporation, Defendant-Appellant.

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

Review Denied May 20, 1997.

Attorney(s) appearing for the Case

Grant Woods, The Attorney General by Gail H. Boyd, Special Assistant Attorney General and Kimberly J. Cygan, Assistant Attorney General, Phoenix, for Plaintiff-Appellee.

Lewis and Roca, L.L.P. by John P. Frank and Patrick Derdenger, Phoenix, and Quarles & Brady by Michael G. Galloway, Phoenix, for Defendant-Appellant.

OPINION

GARBARINO, Judge.

General Motors Acceptance Corporation (GMAC) appeals from the tax court's order granting summary judgment in favor of the Arizona Department of Revenue (ADOR). We agree that the income tax deficiency assessment against GMAC for the tax years between 1976 and 1983 was timely issued pursuant to Arizona Revised Statutes Annotated (A.R.S.) section 42-113(B)(7) (1991).

ISSUES

1. Does the extended limitation...

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