SolarCity Corp. v. Arizona Department of Revenue

OPINION

HOWE, Judge:

¶ 1 In 2013, the Arizona Department of Revenue (“Department”) decided that it could value for taxation purposes solar ener*399gy panels owned by companies that lease and install the panels on their customers’ property for the generation of electricity. The Department determined that the panels could be valued because under the relevant Arizona statutes, the panels were renewable energy equipment that solar power companies used in the operation of an electric generation facility.

¶ 2 Two solar power companies, SolarCity Corporation and SunRun, Inc. (collectively, “Taxpayers”)…