Ariz. Court Affirms Judgment In $2.75M Tax Assessment Suit

Law360, New York (November 26, 2013, 6:32 PM EST) -- Gains from the sale of a wholly owned subsidiary qualify as business income under Arizona tax law, a state appeals court ruled on Tuesday.

In 1999, First Data Corporation sold its wholly owned subsidiary, First Data Investor Services Group, to PNC Bank for a $725 million profit, the opinion says. The taxpayer treated the sale as a complete corporate liquidation, but after an audit, the state of Arizona said it should have been treated as business income and assessed $2.75 million in taxes.

The appeals court...
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