S & R Properties V. Maricopa County

The taxpayers brought separate special actions in the tax court, claiming that each taxpayer's property had been misclassified, and that as a result,  each had paid excessive real property taxes for the years 1985 through 1989. They also alleged that Maricopa County ("the County") and the Arizona Department of Revenue ("DOR") failed to perform duties required by law in refusing to respond to their refund requests and to negotiate in good faith with their agent. The taxpayers requested refunds of the excess taxes pursuant to Ariz. Rev. Stat. Ann. ("A.R.S.") sections 11-505 and -506 (1990).*fn1