Question: Arizona Revised Statute 2 8 - 8 3 3 6 establishes a license tax for a nonresident whose aircraft is based in this state for

Arizona Revised Statute 28-8336 establishes a license tax for a nonresident whose aircraft is based in this state for more than ninety days but less
than two hundred ten days in a calendar year. The Arizona Department of Transportation defined a day (for purposes of taxes and licensing) as any day when the planes tires are on the ground in Arizona, even if those tires were there for only part of a day. The taxpayer says that what counts should be whether the plane was on the ground for a full day. What will the court look at to determine the definition of a day? BSI Holdings, LLC v. Arizona Department of Transportation, 417 P.3d 782(Az.).

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