Brundage-Bone Concrete Pumping, Inc., V. Dept. Of Revenue

CourtCourt of Appeals of Washington
DecidedFebruary 27, 2024
Docket58528-6
StatusUnpublished

This text of Brundage-Bone Concrete Pumping, Inc., V. Dept. Of Revenue (Brundage-Bone Concrete Pumping, Inc., V. 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
Brundage-Bone Concrete Pumping, Inc., V. Dept. Of Revenue, (Wash. Ct. App. 2024).

Opinion

Filed Washington State Court of Appeals Division Two

February 27, 2024

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II BRUNDAGE-BONE CONCRETE No. 58528-6-II PUMPING, INC.,

Appellant,

v. UNPUBLISHED OPINION

STATE OF WASHINGTON, DEPARTMENT OF REVENUE,

Respondent.

MAXA, P.J. – Brundage-Bone Concrete Pumping, Inc. (Brundage-Bone) appeals the trial

court’s order denying its challenge to a Department of Revenue (DOR) rule, WAC 458-20-211

(Rule 211). Brundage-Bone provides concrete pumping services to contractors for use in

construction projects, supplying a concrete pumping truck with an operator to control the pump.

Rule 211 states that stand-alone concrete pumping services will be taxed as retail sales rather

than as wholesale sales.

RCW 82.04.050(9) states that the term “retail sale” includes “the charge made for

providing tangible personal property along with an operator for a fixed or indeterminate period

of time.” However, RCW 82.04.050(14) states that the term retail sale “does not include the sale

for resale of any service described in this section if the sale would otherwise constitute a ‘sale at

retail’ and ‘retail sale’ under this section.” (Emphasis added.) And RCW 82.04.060(3) states No. 58528-6-II

that a “wholesale sale” includes “[t]he sale of any service for resale, if the sale is excluded from

the definition of ‘sale at retail’ and ‘retail sale’ in RCW 82.04.050(14).”

Rule 211(5)(a) states that providing equipment with an operator to a building contractor

generally is classified as a retail sale for B&O tax purposes. Rule 211(6)(a) states that retail

sales tax applies to providing tangible personal property with an operator. However, WAC 458-

20-170 (Rule 170) states that a person who leases equipment to a prime contractor and also

operates the equipment is a subcontractor taxable under the wholesaling classification. Rule

170(1)(b), 3(a).

Before 2019, DOR’s website had a section providing industry guidance regarding the tax

treatment of concrete pumping services. The guidance stated that concrete pumping services for

another contractor was a wholesaling activity subject to B&O tax under the wholesale

classification and not subject to sales tax.

But in August 2019, DOR issued an interim guidance statement to clarify the tax

treatment of certain concrete pumping services. DOR explained that the rental of concrete

pumping equipment with an operator was subject to the retailing B&O tax and retail sales tax.

DOR subsequently incorporated the interim guidance statement into amendments to Rule 211

that were adopted in March 2021.

Brundage-Bone argues that Rule 211 is invalid because (1) the rule exceeds DOR’s

statutory authority by excluding stand-alone concrete pumping services from the definition of a

sale for resale, (2) the rule exceeds DOR’s statutory authority to the extent that it conflicts with

the provisions of Rule 170, and (3) DOR adoption of the 2021 amendments was arbitrary and

capricious.

2 No. 58528-6-II

We hold that (1) because DOR’s interpretation of RCW 82.04.050(9), RCW

82.04.050(14), and RCW 82.04.060(3) in Rule 211 is reasonably consistent with those statutes,

DOR did not exceed its statutory authority by adopting Rule 211; (2) Rule 211 does not exceed

statutory authority simply because it conflicts with Rule 170; and (3) DOR’s 2021 amendments

to Rule 211 were not arbitrary and capricious because DOR duly considered the relevant facts

and circumstances when it adopted the amendments. Accordingly, we affirm the trial court’s

order denying Brundage-Bone’s challenge to Rule 211.

FACTS

Stand-Alone Concrete Pumping Services

Brundage-Bone is a business that provides concrete pumping services to residential,

commercial, and industrial park customers. Their customers include both prime contractors and

subcontractors.

When hired to provide concrete pumping services, Brundage-Bone delivers a concrete

pumping truck to the jobsite with an operator. The contractor purchases concrete from another

vendor, who pours the concrete into the pumping truck’s hopper. Concrete pumping trucks have

powerful pumps with an extendable hose. The operator controls the pump to discharge concrete

as instructed by the contractor. The contractor provides the workers responsible for placing and

finishing the pumped concrete.

Statutory Change and 1996 Amendments to Rule 211

RCW 82.04.050 defines what transactions are classified as “retail sales” for tax purposes.

A retail sale generally is defined as “every sale of tangible personal property . . . to all persons

irrespective of the nature of their business.” RCW 82.04.050(1)(a).

3 No. 58528-6-II

In 1993, the legislature amended RCW 82.04.050 to include in the definition of retail sale

“the rental of equipment with an operator.” Former RCW 82.04.050(4) (1993).1 In 1996, DOR

incorporated that statutory change into its Rule 211. See Former WAC 458-20-211 (1996)

(former Rule 211). Provisions of the amended Rule 211 stated that renting equipment with an

operator generally is a retail sale, former Rule 211(5)(b), and the lessee is not purchasing the

equipment for resale. Former Rule 211(4). And the 1996 amendments included an example

specific to concrete pumping:

XYZ Concrete Pumping is hired by a prime contractor to supply a concrete pump and operator to pump concrete from a premix concrete delivery truck to the location of the forms. XYZ has no responsibility to build forms, do the concrete finishing, or otherwise see that the concrete meets or is placed according to contract specifications. In short, the pump functions similarly to a wheelbarrow, but in a more efficient manner. XYZ is not a subcontractor and is making a retail rental of equipment with an operator.

Former Rule 211(8)(c).

DOR Industry Guidance and Interim Guidance Statement

For some time before 2019, DOR’s website listed industry guidance for how certain

activities are classified for tax purposes. The guidance included a section specifically related to

concrete pumping services:

Concrete pumping services are considered to be construction services. As such, concrete pumping for a landowner is a retail sale and subject to sales tax. Income received from this activity is subject to B&O tax under the Retailing classification.

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