Arizona Tractor Co. v. Arizona State Tax Commission

OPINION

JACOBSON, Presiding Judge.

The sole issue to be determined by this appeal is whether the losses (income) incurred by a domestic corporation’s ownership in a limited partnership doing business in another state are deductible (taxable) on the domestic corporation’s Arizona income tax return.

The facts giving rise to this issue are not in dispute. During the fiscal tax years of 1969, 1970 and 1971, appellant, Arizona Tractor Company (Arizona Tractor), an Arizona corporation, deducted from its Arizona income tax its proportionate share of losses incurred by a partnership known as Brendon Way…