Brink Electric Constr. Co. v. Arizona Dep't of Revenue
In Brink Electric Constr. Co. v. Arizona Dep't of Revenue, 184 Ariz. 354, 358, 909 P.2d 421, 425 (App. 1995), the taxpayer argued that A.A.C. R15-5-608, which stated that "installation of equipment which becomes permanently attached in a plant or other structure is taxable as a contracting activity," stood for the proposition that there could be no "contracting" with respect to equipment that did not become permanently attached.
The Court disagreed and held that "the regulation certainly includes permanent attachment of equipment to a structure within the scope of contracting, but does not purport to exclude other real property improvements." Id. at 360 n.6, 909 P.2d at 427 n.6.