Myrtle Manor Apartments v. City of Phoenix

OPINION

GARBARINO, Judge.

Taxpayers Myrtle Manor Apartments and Momingside Villa Apartments appeal from a judgment in favor of the City of Phoenix on refund claims for Phoenix privilege taxes assessed on sums the taxpayers received under housing assistance payment (HAP) contracts funded by the United States Department of Housing and Urban Development (HUD). The City cross-appeals from the tax court’s holding that the value of the taxpayers’ on-site managers’ use of apartment units was not includable in the taxpayers’ gross income. We consider:(1) Whether the tax court erred in holding that HUD…