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SIERRA TUCSON, INC. v. PIMA COUNTY

No. 1 CA-TX 92-0014.

178 Ariz. 215 (1994)

871 P.2d 762

SIERRA TUCSON, INC., an Arizona corporation, Sierra Tucson/Arizona Holdings, Inc., an Arizona corporation, Sierra Tucson Companies, Inc., a Delaware corporation, and Sierra Tucson Educational Materials, Inc., an Arizona corporation, Plaintiffs-Appellants, v. PIMA COUNTY, a body politic; the Arizona Department of Revenue, a department of the State of Arizona, Pima County Assessor; Pima County Board of Supervisors, Defendants-Appellees.

Court of Appeals of Arizona, Division 1, Department T.

March 31, 1994.

Attorney(s) appearing for the Case

Hecker, Phillips & Zeeb by Kenneth R. Moeller, Tucson, for plaintiffs-appellants.

Stephen D. Neely, Pima County Atty. by Alison K. North, Tucson, for defendants-appellees.

OPINION

GARBARINO, Judge.

Taxpayers Sierra Tucson, Inc., and related corporations (Sierra Tucson) appeal from a tax court judgment determining that four parcels of real property were classified as class three commercial property for ad valorem tax purposes.

ISSUES

Sierra Tucson presents the following issues on appeal:

(1) whether the tax court erred in holding that Sierra Tucson's property was not "structured to the care...

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