State ex rel. Dep't of Revenue v. Talley Indus., Inc
In State ex rel. Dep't of Revenue v. Talley Indus., Inc., 182 Ariz. 17, 25, 893 P.2d 17, 25 (App. 1994), "centralized management and control, and the parent's provision of financing, research, legal, accounting and other internal services to its subsidiaries" existed but those services could be measured and were not subsumed in the products. Id. at 25, 893 P.2d at 25.
The Court recognized that "substantial transactions, interrelations or interdependence of basic operations among the various income-earning subsidiaries" might create difficulty in apportioning income in some cases, but no such interdependence existed among the entities in the allegedly unitary group. Id.