Stillwell Grand Prix Motors, Inc. v. City of Tucson

*561OPINION

BROOKS, Judge.

Stillwell Grand Prix Motors, Inc., (Still-well) appeals from a summary judgment upholding an assessment of business privilege taxes by the city of Tucson. The tax, which took the form of a retail sales tax, was imposed upon the gross proceeds of sales of BMW and Saab automobiles that were delivered to their purchasers in Europe. On appeal, Stillwell argues that its activities in conjunction with the European delivery program were not sales within the meaning of the Tucson Code provisions governing the retail sales tax. It maintains that BMW and Saab were the sellers…