A.R.S. § 42-16206: Appeal to court by the director

A. If, in the director's opinion, a decision by a county board of equalization or the state board of equalization is erroneous, the director may appeal the decision to superior court in the manner provided by this article on or before the final date that a taxpayer may file an appeal from the valuation or classification of property.

B. In such an action the taxpayer shall raise any defense that the taxpayer has to liability for the tax and any additional tax sought to be imposed.

C. If issues other than valuation or classification are raised by either party, the action shall be tried as if it were an action pursuant to section 42-11005 or 42-11052.