Valencia Energy Co. v. Arizona Department of Revenue

LANKFORD, Presiding Judge.

Following a transaction privilege (sales) tax audit for the period between November 1985 and March 1990, the Department of Revenue (“DOR”) concluded that Valencia Energy Company owed $4.98 million in taxes plus interest. Valencia succeeded only in part when it administratively challenged the assessment of back taxes, so it appealed to the tax court. In a published opinion, the tax court granted summary judgment in favor of DOR, upholding the assessment of back taxes and interest. Valencia Energy Co. v. Arizona Dep’t of Revenue, 178 Ariz. 251, 872 P.2d 206 (Tax 1994).…