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BSI HOLDINGS v. ARIZONA DEP'T OF TRANSP.

No. 1 CA-TX 20-0005.

498 P.3d 119 (2021)

BSI HOLDINGS LLC, Plaintiff/Appellee, v. ARIZONA DEPARTMENT OF TRANSPORTATION, Defendant/Appellant.

Court of Appeals of Arizona, Division 1.

FILED August 12, 2021.

Attorney(s) appearing for the Case

Ryan Rapp Underwood & Pacheo, PLC, Phoenix, By Christopher T. Rapp , Lesli M. H. Sorensen , Counsel for Plaintiff/Appellee.

Arizona Attorney General's Office, Phoenix, By Benjamin H. Updike , Counsel for Defendant/Appellant.

Judge Lawrence F. Winthrop delivered the opinion of the Court, in which Presiding Judge Paul J. McMurdie and Judge Cynthia J. Bailey joined.

OPINION

¶1 Arizona authorizes the imposition of a state license tax on nonresident aircraft owners equal to one-tenth of one per cent of the fair market value of the aircraft. A.R.S. § 28-8336. An aircraft subject to this tax (1) must not be engaged in any intrastate...

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