Arizona Department of Revenue v. General Motors Acceptance Corp.

OPINION

GARBARINO, Judge.

General Motors Acceptance Corporation (GMAC) appeals from the tax court’s order granting summary judgment in favor of the Arizona Department of Revenue (ADOR). We agree that the income tax deficiency assessment against GMAC for the tax years between 1976 and 1983 was timely issued pursuant to Arizona Revised Statutes Annotated (A.R.S.) section 42-113(B)(7) (1991).

ISSUES

1. Does the extended limitation period provided by A.R.S. section 42-113(B)(7) for assessing Arizona income tax deficiencies based on the existence of an agreement between the taxpayer and the United…