In Honeywell Bull, Inc. v. Arizona Department of Revenue, Ariz. Bd. Tax. App. No. 646-89-S, January 23, 1990, the tax court of appeals found two transactions in a sale and leaseback agreement. In Honeywell, Blue Cross of Arizona entered into an agreement wherein Blue Cross sold its computer to CAR and CAR leased the equipment back to Blue Cross. The Arizona Department of Revenue determined that two transactions occurred: (1) Blue Cross's sale of the computer to CAR, and (2) the leaseback of the computer by Blue Cross. The Honeywell court rejected the taxpayer's argument that it intended the agreement to be one transaction, stating that such an argument was not a "sufficient basis" to justify treating it as a single transaction. Id.