Better Business Bureau Great West And The Pacific, V State Dept. Of Revenue

CourtCourt of Appeals of Washington
DecidedSeptember 10, 2024
Docket58492-1
StatusUnpublished

This text of Better Business Bureau Great West And The Pacific, V State Dept. Of Revenue (Better Business Bureau Great West And The Pacific, V State Dept. Of Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Better Business Bureau Great West And The Pacific, V State Dept. Of Revenue, (Wash. Ct. App. 2024).

Opinion

Filed Washington State Court of Appeals Division Two

September 10, 2024

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II BETTER BUSINESS BUREAU GREAT No. 58492-1-II WEST† & THE PACIFIC,

Appellant,

v. UNPUBLISHED OPINION

WASHINGTON STATE DEPARTMENT OF REVENUE,

Respondent.

CHE, J. ⎯ The Better Business Bureau Great West and the Pacific (BBB) appeals the trial

court’s grant of the Department of Revenue’s (DOR) motion for summary judgment, denial of

BBB’s motion for partial summary judgment, grant of the DOR’s protective order, and denial of

BBB’s motion to compel discovery.

BBB sought a refund of business and occupation (B&O) taxes paid in 2017. BBB

claimed that the accreditation fees (membership dues) it received from its members were “bona

fide dues” under RCW 82.04.4282 and thus fully deductible from its gross income. The DOR

maintained that because BBB failed to provide any evidence showing what portion, if any, of the

membership dues qualified for the deduction, the membership dues are fully taxable. The parties

also disputed whether a DOR memo related to BBB’s taxability should be redacted and disclosed

in discovery. The parties filed cross motions for summary judgment. The trial court granted the

† Also captioned as Better Business Bureau Northwest. No. 58492-1-II

DOR’s motion for summary judgment, denied BBB’s motion for partial summary judgment,

granted the DOR’s protective order, and denied BBB’s motion to compel discovery.

BBB argues that summary judgment was inappropriate because (1) collateral estoppel

bars the DOR’s claim; (2) the ability to display BBB’s seal, the members’ rating, and the

members’ accreditation status does not confer a “significant amount” of goods or services to

members; and (3) the DOR admitted the existence of a genuine issue of material fact—that a

portion of the dues was tax deductible. BBB also argues that the trial court erred in denying its

motion to compel discovery of the memo because it was discoverable under CR 26 and 34.

We hold (1) collateral estoppel does not apply, (2) the trial court did not err in granting

summary judgment in favor of the DOR, and (3) the memo is wholly exempt from disclosure.

Accordingly, we affirm the trial court’s grant of the DOR’s motions for summary

judgment and protective order, and its denial of BBB’s motions for partial summary judgment

and to compel discovery.

FACTS

A. Tax Ruling and Tax Refund Action

BBB is a non-profit corporation that provides to businesses and consumers in various

states, including Washington, services to promote the “‘creation of a community of trustworthy

businesses,’” protection of consumers, and encouragement of best business practices, among

other things. Clerk’s Papers (CP) at 3.

BBB offers accredited membership to businesses. BBB collects annual membership

dues. Once BBB accepts a member, BBB generally authorizes the member to advertise its BBB

accreditation and use BBB trademarks. Among other benefits, members may display their

2 No. 58492-1-II

accreditation plaque and decal, use the BBB seal, advertise its BBB rating, and identify as an

accredited business in online and offline advertising.

In 2019, the DOR requested BBB to verify its active non-reporting status. BBB

requested a tax ruling from the DOR. The DOR issued its ruling, concluding that under RCW

82.04.4282, BBB’s membership dues are paid in exchange for “significant services” and are

therefore subject to B&O tax. CP at 76.

BBB requested the DOR to conduct an administrative review of the tax ruling. Attached

to its request, BBB included the findings of fact and conclusions of law from a 1981 trial court

decision (1981 ruling). In that case, BBB and the DOR litigated the issue of whether BBB’s

membership dues qualified for a tax deduction under RCW 82.04.4282(2). In its 1981 ruling, the

trial court determined BBB showed its entitlement to a B&O tax deduction for all dues received.

The trial court found the dues were bona fide dues that “[were] not for or graduated upon the

amount of services rendered to the member or members.” CP at 87.

The DOR affirmed its 2019 tax ruling. In its determination, the DOR concluded that

“some” of BBB’s services are “not significant services provided in exchange for the membership

fee because they are not services that [BBB’s] members would pay a charge for in the

marketplace.” CP at 912. These tax-deductible services included listing members in BBB’s

online business directory, populating customer reviews for online business listings, and using the

“request a quote feature.” CP at 913. The DOR further concluded that BBB provides its

members “two services of a significant value: accreditation and discount advertising.” CP at

913.

3 No. 58492-1-II

The DOR determined that since BBB “has not submitted evidence of the portion of its

dues that cover the expenses for providing the privileges of membership . . . the DOR presumes

that the entire amount of dues income is taxable.” CP at 913. BBB did not file an appeal of the

DOR’s determination.

The DOR subsequently audited BBB and assessed $139,653.45 in B&O taxes against

BBB for the 2017 tax period. BBB paid the B&O taxes, which prompted BBB to file this tax

refund action for the 2017 tax period.1 BBB claimed its membership dues were “bona fide dues”

under RCW 82.04.4282 and thus deductible from its B&O tax liability. CP at 32.

B. Discovery

The parties engaged in discovery. Among other requested documents, the DOR withheld

a two-page memo written by a tax information specialist, which was a “very quick and brief

summary of information about [BBB] and [the DOR’s] thoughts about [BBB’s] taxability.” CP

at 441. The DOR asserted a privilege under RCW 82.32.330, stating the memo “[d]iscusses

Confidential Tax Information of another taxpayer, and therefore [is] precluded from disclosure.”

CP at 67.

The DOR subsequently moved for a protective order under CR 26(c) to withhold the

memo in its entirety. BBB moved to compel discovery of the memo under CR 26 and 34. The

trial court heard oral argument on the parties’ cross-discovery motions, granted the DOR’s

motion, and denied BBB’s motion.

1 In January 2022, BBB amended its complaint, seeking to obtain a tax refund for amounts paid in the 2017 tax period, rather than the 2016 tax period.

4 No. 58492-1-II

The trial court issued a protective order on the grounds that RCW 82.32.330 protects the

memo from production in its entirety. The trial court entered an order consistent with its ruling

at oral argument.

C. Summary Judgment Motions

The DOR moved for summary judgment, seeking a determination that BBB did not show

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Washington Federation of State Employees v. State Personnel Board
630 P.2d 951 (Court of Appeals of Washington, 1981)
Cowiche Canyon Conservancy v. Bosley
828 P.2d 549 (Washington Supreme Court, 1992)
DeHeer v. Seattle Post-Intelligencer
372 P.2d 193 (Washington Supreme Court, 1962)
GROUP HEALTH CO-OP. OF PUGET SOUND, INC. v. State Tax Comm'n
433 P.2d 201 (Washington Supreme Court, 1967)
Sligar v. Odell
233 P.3d 914 (Court of Appeals of Washington, 2010)
Hadley v. Maxwell
27 P.3d 600 (Washington Supreme Court, 2001)
Automobile Club v. Department of Revenue
621 P.2d 760 (Court of Appeals of Washington, 1980)
DOT FOODS v. Washington Dept. of Revenue
215 P.3d 185 (Washington Supreme Court, 2009)
Paul A. Scholz v. Washington State Patrol
416 P.3d 1261 (Court of Appeals of Washington, 2018)
Matthew & Amy Johnson v. Lake Cushman Maintenance Co.
425 P.3d 560 (Court of Appeals of Washington, 2018)
Christopher W. Sartin v. Alonzo Mcpike
475 P.3d 522 (Court of Appeals of Washington, 2020)
Hadley v. Maxwell
144 Wash. 2d 306 (Washington Supreme Court, 2001)
Christensen v. Grant County Hospital District No. 1
96 P.3d 957 (Washington Supreme Court, 2004)
Dot Foods, Inc. v. Department of Revenue
166 Wash. 2d 912 (Washington Supreme Court, 2009)
Dot Foods, Inc. v. Department of Revenue
372 P.3d 747 (Washington Supreme Court, 2016)
Sligar v. Odell
156 Wash. App. 720 (Court of Appeals of Washington, 2010)
Analytical Methods, Inc. v. Department of Revenue
928 P.2d 1123 (Court of Appeals of Washington, 1996)

Cite This Page — Counsel Stack

Bluebook (online)
Better Business Bureau Great West And The Pacific, V State Dept. Of Revenue, Counsel Stack Legal Research, https://law.counselstack.com/opinion/better-business-bureau-great-west-and-the-pacific-v-state-dept-of-revenue-washctapp-2024.