Sundevil Power Holdings, LLC v. Arizona Department of Revenue

OPINION

HOWE, Judge:

¶ 1 The Arizona Department of Revenue (“Department”) and Maricopa County (“County”) appeal the tax court’s summary judgment in favor of Sundevil Power Holdings, LLC (“Taxpayer”) for tax years 2013, 2014, and 2015. The Department and the County argue that the court erred in granting summary judgment because it incorrectly applied A.R.S. § 42-14156 (“valuation statute”) and erred in allowing Taxpayer’s 2013 amended complaint to relate back to the date of the original complaint. Because the tax court did not err in interpreting the valuation statute, but did err in allowing…