First Data Corp. v. Arizona Department of Revenue

OPINION

GEMMILL, Judge.

¶ 1 First Data Corporation (“Taxpayer”) challenges the Arizona Tax Court’s holding that gains from the sale of a wholly-owned subsidiary are business income on its Arizona combined income tax return. Taxpayer challenges the interpretation of “business income” adopted by the Arizona Department of Revenue (“Department”) and the tax court. We resolved a related issue presented in Harris Corp. v. Ariz. Dep’t of Revenue, 233 Ariz. 377, 312 P.3d 1143 (App.2013) concerning the interpretation of the “business income” definition under Arizona Revised Statutes (“AR.S.”) section…