ADP V DOR JUDGMENT TX2018-000246.PDF

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
MARK BRNOVICH
Attorney General
Firm Bar No. 14000
Scot G. Teasdale (019330)
Nancy K. Case (028802)
Assistant Attorneys General
2005 North Central Avenue
Phoenix, AZ 85004-1592
(602) 542-8382 / (602) 542-8356
tax@azag.gov
Attorneys for Arizona Department of Revenue
THE SUPERIOR COURT OF THE STATE OF ARIZONA 
IN THE ARIZONA TAX COURT
ADP, LLC, a Delaware limited liability 
company,
Plaintiff,
v.
ARIZONA DEPARTMENT OF REVENUE, 
an agency of the State of Arizona,
Defendant.
Cause No. TX2018-000246
Consolidated
JUDGMENT
ADP, LLC, a Delaware limited liability
Company,
Plaintiff,
v.
ARIZONA DEPARTMENT OF REVENUE, 
an agency of the State of Arizona; CITY OF 
PHOENIX, ARIZONA, a charter city and 
political subdivision of the State of Arizona,
Defendants.
Granted with Modifications
Granted with Modifications
Granted with Modifications
Granted with Modifications
***See eSignature page***
Clerk of the Superior Court
*** Electronically Filed ***
K. Cabral, Deputy
9/9/2021 8:00:00 AM
Filing ID 13350522

2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
ADP, LLC, a Delaware limited liability
Company,
Plaintiff,
v.
CITY OF PHOENIX, ARIZONA, a charter 
city and political subdivision of the State of 
Arizona,
Defendant.
The Court having granted the Department of Revenue’s Motion for Summary Judgment
filed August 11, 2020 and the City of Phoenix’s Motion for Summary Judgment filed August 
19, 2020, and having denied Plaintiff’s Cross Motion for Summary Judgment Against 
Defendant Arizona Department of Revenue filed November 13, 2020 as stated in its July 8, 
2021 Minute Entry Under Advisement Ruling,
IT IS ORDERED, ADJUDGED, AND DECREED that
1.
Department’s motion for summary judgment is granted.
2.
City of Phoenix’s motion for summary judgment is granted.
3.
Plaintiff’s motion for summary judgment is denied.
4.
Plaintiff’s June 16, 2014 claim for a refund of Arizona state and county transaction 
privilege tax in the amount of $155,000.17 (reduced from $206,315.34 during the 
administrative hearing process) for the period of June 1, 2011 through April 30, 
2014 is denied. 
5.
Plaintiff’s June 23, 2017 claim for a refund of City of Phoenix municipal privilege 
license tax in the amount of $45,528.12 for the period of June 1, 2011 through 
April 30, 2014 is denied.

3
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
6.
Plaintiff’s April 30, 2018 claim for a refund of Arizona state and county transaction 
privilege and related taxes in the amount of $182,695.06 and City of Phoenix 
municipal privilege license tax in the amount of $17,821.05 for the period of May 
1, 2014 through March 31, 2018 is denied.
7.
Pursuant to A.R.S. §§ 12-332, -341 and 44-1201(B), the Department is awarded its 
taxable costs in the amount of $1,014.70.  The City of Phoenix did not submit any 
taxable costs.
IT IS FURTHER ORDERED that no issues remain pending and this Judgment is entered 
pursuant to Rule 54(c), Arizona Rules of Civil Procedure. 
DATED this 
day of _________________, 2021.
  
Honorable Danielle J. Viola
Maricopa County Superior Court

Granted with Modifications
Granted with Modifications
Granted with Modifications
Granted with Modifications
/S/ Danielle Viola Date: 9/8/2021
_____________________________
Judicial Officer of Superior Court
eSignature Page 1 of 1
eSignature Page 1 of 1
eSignature Page 1 of 1
eSignature Page 1 of 1
                                    Filing ID: 13350522   Case Number: TX2018-000246
                                                      Original Filing ID: 13165223
_______________________________________________________________________________

ENDORSEMENT PAGE
ENDORSEMENT PAGE
ENDORSEMENT PAGE
ENDORSEMENT PAGE
CASE NUMBER: TX2018-000246
SIGNATURE DATE: 9/8/2021
E-FILING ID #: 13350522
FILED DATE: 9/9/2021 8:00:00 AM
MICHAEL G GALLOWAY
SCOT G TEASDALE
SCOTT G ANDERSEN