GARBARINO, Presiding Judge.
¶ 1 This appeal presents the question whether a wholly owned subsidiary, existing only to hold title to real property used by its parent company, is subject to City of Phoenix (the City) privilege license (excise) taxes as a business leasing real property for a consideration. Here, the tax court granted summary judgment for the taxpayer, Construction Developers, Inc. (CDI), regarding its claim to set aside the City's excise tax assessment...
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