South Point Energy Center, LLC v. Arizona Department of Revenue

OPINION

SWANN, Judge:

¶1 South Point Energy Center, LLC (“South Point”) appeals the tax court’s entry of summary judgment in favor of the Arizona Department of Revenue and Mohave County (collectively, “Defendants”) on South Point’s actions challenging the assessment of property taxes. The tax court concluded that South Point was collaterally estopped from challenging the legality of the taxes and that relief was not available under the error-correction statutes. We disagree. First, issue preclusion did not apply because South Point’s challenges were based on an issue not raised in previous…