OPINION
HATHAWAY, Judge.
Lincoln Property Co. [L.P.] has appealed from a judgment entered against it in its suit for refund of Tucson business privilege taxes paid under protest. The matter was submitted to the trial court on a fact stipulation and cross-motions for summary judgment. The issues on appeal, as framed by appellants, are:
1. Whether it was proper for the City of Tucson to apply its business privilege tax on "contracting" to the non-contracting...
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