Court of Appeals of Arizona June 5, 2007, 1 CA-TX 06-0006 (Arizona Department of Revenue v. Action Marine, Inc.)

OPINION

WEISBERG, Judge.

¶ 1 Action Marine, Inc., and Melvin Randall, Martha Randall, M. Daniel Randall, Lisa Randall, John D. Randall, and Belinda Randall (collectively, “the Randalls”) appeal the tax court’s grant of summary judgment in favor of the Arizona Department of Revenue (“ADOR”) and the denial of their motion for a new trial. For the reasons discussed below, we reverse.