ADVO System, Inc. v. City of Phoenix

OPINION

VOSS, Judge.

Taxpayer ADVO System, Inc. (the taxpayer or ADVO), brought this action in the tax court for a refund of $358,346.67 paid under protest on an assessment for City of Phoenix privilege license taxes, penalties and interest for the audit period January 1984 through December 1989. The City counterclaimed for an additional $64,268.89 in taxes that was abated during the administrative process. The taxpayer appeals, and the City cross-appeals, from a judgment entered on cross-motions for summary judgment. These issues are presented:

1. Whether those portions of ADVO’s business…