City of Phoenix v. Santa Anita Development Corp.

OPINION

FROEB, Judge.

This case involves an interpretation of the City of Phoenix privilege license tax ordinance effective prior to January 1, 1978.

Where an owner of real property pays a contractor to construct improvements thereon and thereafter sells the improved real property, are the revenues received from such sale revenues from the business of “contracting” within the city sales tax?

Appellant City of Phoenix (hereafter referred to as the City) assessed Santa Anita Development Corporation and Shopping Center Ventures, Inc., (sometimes referred to as the taxpayers) as “contractors”…