Arizona – Goodwill receipts excluded from sales factor

September 2013


The Arizona Department of Revenue found that a taxpayer’s receipts attributable to goodwill in a deemed asset sale qualified for exclusion from the sales factor as substantial amounts of gross receipts arising from an incidental or occasional sale. The Department reasoned that Arizona’s regulation addressing occasional sales of fixed assets should be applied to revenue from intangible property, like goodwill.  [Arizona DOR Hearing Office Decision No. 201200235-C (5/31/2013)]

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