R.R. Donnelley & Sons Co. v. Arizona Department of Revenue

OPINION

BARKER, Judge.

¶ 1 This is a corporate income tax case. The Arizona Department of Revenue (the “Department” or “ADOR”) appeals the Arizona Tax Court’s grant of summary judgment in favor of R.R. Donnelley & Sons Co. (“Taxpayer”), R.R. Donnelley Receivables, Inc. (“Receivables”), Heritage Preservation Corp. (“Heritage”), and Caslon Inc. (“Cas-lon”) (the latter three, collectively, the “Subsidiaries”). The tax court upheld Taxpayer’s right to exclude Receivables and Caslon from its combined Arizona tax return but required it to include Heritage. Taxpayer cross-appeals from the portion of…