Valencia Energy Co. v. Arizona Department of Revenue
Arizona Supreme Court
1Opinion of the Court
OPINION
FELDMAN, Justice.
¶ 1 The Arizona Department of Revenue (“Department”) audited Valencia Energy Company (“Valencia”) and assessed a deficiency. The court of appeals affirmed the grant of summary judgment against Valencia. We granted review to determine whether the Department can be estopped from collecting back taxes owed because a Department agent advised Valencia in writing that the activity now levied on was not subject to tax. We have jurisdiction pursuant to Ariz. Const, art. VI, § 5(3) and A.R.S. § 12-102.
FACTS AND PROCEDURAL HISTORY
¶ 2 We view the facts in the light most favorable…
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