Devenir Associates v. City of Phoenix

OPINION

MORONEY, Judge.

The taxpayer-plaintiffs are a number of partnerships, all of whose partners are also partners of the same law firm. Each taxpayer partnership was formed by partners of the law firm to buy personal property which the buying partnership then leased to the law firm.

A different taxpayer partnership was formed every year. All of the non-expendable personal property required by the law firm was subject to purchase by the taxpayer partnership that was the then current most recently formed partnership.

For the relevant tax year, each taxpayer partnership owned the personal…