State ex rel. Arizona Department of Revenue v. Control Data Corp.

OPINION

EUBANK, Judge.

This appeal concerns the Arizona Transaction Privilege Tax, A.R.S. § 42-1301 et seq., and an exemption therein relating to “sales” made directly to the United States Government. Control Data Corporation, defendant-appellee, was audited and assessed for taxes allegedly due on rental receipts for equipment leased to the United States Government, Department of the Army.1 Control Data protested the assessment in the Arizona Board of Tax Appeals, which held that the receipts in question were exempt from taxation. The Arizona Department of Revenue then initiated an action in…