Somehow, every Arizona factory and wholesaler selling parts to us became our branch office when we asked them to ship directly to our customers. Address labels became stores, refrigerator magnets became salespeople and, magically, RockAuto was in Arizona.

No previous court case (including ours in the Arizona Tax Court) found a retailer "physically present" without employees or assets or someone making in-state contact with customers. ADoR's own publications say "drop-shipping" from Arizona suppliers does not create tax liability. But ADoR persists in demanding six years of taxes (which we didn't collect from customers) plus interest and penalties — far more money than we earned in 20 years selling auto parts to Arizonans!