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HOME DEPOT USA v. ARIZ. DEPT. OF REVENUE

No. 1 CA-TX 11-0004.

287 P.3d 97 (2012)

HOME DEPOT USA, INC., Plaintiff/Appellant, v. ARIZONA DEPARTMENT OF REVENUE, Defendant/Appellee.

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

October 2, 2012.

Attorney(s) appearing for the Case

Steptoe & Johnson LLP by Pat Derdenger Bennett Evan Cooper , Phoenix and Gibson, Dunn & Crutcher LLP by Randy M. Mastro* , Jennifer H. Rearden* , Georgia K. Winston* , New York, NY, Evan S. Tilton*,* admitted pro hac vice, Dallas, TX, Attorneys for Plaintiff/Appellant.

Thomas C. Horne , Arizona Attorney General by Scot G. Teasdale , Assistant Attorney General, Phoenix, Attorneys for Defendant/Appellee.

OPINION

SWANN, Judge.

¶ 1 This is a transaction privilege tax case. Home Depot USA, Inc. ("Taxpayer") challenges the superior court's entry of summary judgment denying its claim for a tax refund based on bad debt deductions under A.A.C. R15-5-2011(A). For the reasons that follow, we affirm the judgment.

FACTS AND PROCEDURAL HISTORY

¶ 2 Taxpayer operates retail home-improvement stores throughout the United States, including...

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