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ADP, LLC v. ARIZONA DEPT. OF REVENUE

No. 1 CA-TX 21-0009.

524 P.3d 278 (2023)

ADP, LLC, a Delaware limited liability company, Plaintiff/Appellant, v. ARIZONA DEPARTMENT OF REVENUE, an agency of the State of Arizona; City of Phoenix, Arizona, a charter city and political subdivision of the State of Arizona, Defendants/Appellees.

Court of Appeals of Arizona, Division 1.

Filed January 31, 2023.

Attorney(s) appearing for the Case

Ryan Rapp Underwood & Pacheco PLC, Phoenix, By Lesli M. H. Sorensen (argued), Michael G. Galloway , Ian A., Macpherson , Christopher T. Rapp , Counsel for Plaintiff/Appellant.

Arizona Attorney General's Office, Phoenix, By Scot G. Teasdale (argued), Counsel for Defendant/Appellee Arizona Department of Revenue.

Wright Welker & Pauole PLC, Phoenix, By Scott G. Andersen (argued), Richard R. Carpenter , Counsel for Defendant/Appellee City of Phoenix.

The Cavanagh Law Firm P.A., Phoenix, By James G. Busby, Jr. , Karen C. Stafford , Counsel for Amicus Curiae Arizona Tax Research Association, Chamber of Commerce and Industry, Arizona Technology Council, and Ryan LLC.

Presiding Judge Brian Y. Furuya delivered the opinion of the Court, in which Judge Jennifer B. Campbell and Judge Paul J. McMurdie joined.

OPINION

¶1 ADP, LLC ("ADP") appeals from the superior court's grant of summary judgment in favor of the Arizona Department of Revenue ("ADOR") and the City of Phoenix ("the City"), finding that ADP's contract with Maricopa County is subject to Transaction Privilege Tax ("TPT"). For the following reasons, we affirm....

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