Harris Corp. v. Arizona Department of Revenue

OPINION

GEMMILL, Judge.

¶ 1 The issue in this corporate taxation ease is whether certain income constitutes “business income” or “nonbusiness income” under Arizona Revised Statutes (“A.R.S.”) section 43-1131. The definition of “business income” in A.R.S. § 43-1131(1) is set forth in two clauses. We hold that Arizona may tax corporate income as “business income” if the income satisfies either definitional clause. Because the tax court correctly applied the statute to the facts, we affirm the tax court’s grant of summary judgment to the Arizona Department of Revenue (the “Department”).

BACKGROUND

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