Brink Electric Construction Co. v. Arizona Department of Revenue

OPINION

LANKFORD, Judge.

In this consolidated appeal, the Arizona Department of Revenue (ADOR) appeals from tax court judgments in favor of taxpayers Blink Electric Construction Company (Brink) and Ball, Ball & Brosamer, Inc. (Ball). The tax court held that ADOR violated Brink’s and Ball’s right to equal protection of the law by arbitrarily requiring a purchasing agent relationship between a contractor and an owner to obtain a transaction privilege tax exemption. The tax court also held that in installing electrical transmission equipment, Brink made tax-exempt retail sales to the project…