DISH Network, LLC v. Dep't of Revenue

CourtCourt of Appeals of Washington
DecidedSeptember 26, 2023
Docket39496-4
StatusUnpublished

This text of DISH Network, LLC v. Dep't of Revenue (DISH Network, LLC v. Dep't 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
DISH Network, LLC v. Dep't of Revenue, (Wash. Ct. App. 2023).

Opinion

FILED SEPTEMBER 26, 2023 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

DISH NETWORK, LLC, a Colorado ) No. 39496-4-III limited liability company, ) ) Respondent / Cross Appellant, ) ) v. ) UNPUBLISHED OPINION ) STATE OF WASHINGTON, ) DEPARTMENT OF REVENUE, ) ) Appellant / Cross Respondent. )

PENNELL, J. — This case involves cross appeals of a tax refund decision. The trial

court decided DISH Network, LLC (DISH) was entitled to a refund of penalties and

a partial refund of interest after the Department of Revenue misstated DISH’s tax

obligation calculations through an inaccurate audit worksheet. Dissatisfied with this

result, DISH argues it should get a full refund. Also dissatisfied, the Department claims

DISH is not entitled to any refund. Both sides take their positions too far. While we do

not agree with all of the trial court’s analysis, we affirm the court’s ultimate disposition. No. 39496-4-III DISH Network, LLC v. Dep’t of Revenue

FACTUAL AND PROCEDURAL BACKGROUND

DISH 1 is a Colorado-based nationwide provider of direct-to-home satellite

television service. DISH incurs the majority of its operation costs in states other than

Washington. One of DISH’s largest expenses is the cost associated with buying television

programming from content providers (programming costs), which DISH then delivers to

viewers through satellite dishes.

Washington imposes a business and occupation (B&O) tax on “every person that

has a substantial nexus with this state . . . for the act or privilege of engaging in business

activities.” RCW 82.04.220(1). The tax is levied against the taxpayer’s gross sales. Id.

For a taxpayer like DISH, whose sales are taxable in multiple states, the tax applies only

to income that is apportioned to Washington. RCW 82.04.460(1). Apportionment of

income is based on the portion of income derived from services rendered within the state.

Id. During the time relevant to the parties’ suit, Washington’s B&O statute specified that

apportionment of income should be calculated using the “cost apportionment” method

if it could not accurately be calculated by what is known as the “separate accounting”

1 DISH was previously called Echostar Satellite, LLC (Echostar). The company is identified as DISH starting with its May 2008 Washington excise tax return. DISH and Echostar are the same entity, and the taxpayer identification number remained the same after the name change. For simplicity and readability, we refer to the company as DISH even though in the record on review it is also identified as Echostar.

2 No. 39496-4-III DISH Network, LLC v. Dep’t of Revenue

method. Former RCW 82.04.460(1) (2004). 2

In the late 1990s and early 2000s, the Department conducted audits of DISH that

addressed questions regarding whether DISH owed B&O taxes and, if so, what method

should be used for calculating income. The audits resulted in written administrative

rulings explaining that DISH was responsible for paying B&O taxes and that it must use

the cost apportionment method in calculating its taxable income.

Effective January 1, 2006, the Department made extensive amendments to

former WAC 458-20-194 (1983) (also known as Rule 194) to provide more detailed

and specific guidance on calculating tax by the cost apportionment method. See Wash. St.

Reg. 05-24-054. Rule 194 would now explain that cost apportionment was the ratio of the

cost of doing business in Washington divided by a company’s worldwide business costs.

WAC 458-20-194(4)(a)(ii).

In February 2007, the Department completed an audit of DISH’s excise tax returns

for the period running from January 1 through June 30, 2004. The audit resulted in an

assessment of additional tax. As explanation, the Department asserted DISH should have

2 “‘Separate accounting’ refers to a method of accounting that segregates and identifies sources or activities that account for the generation of income within the state of Washington. Separate accounting is distinct from cost apportionment, which assigns a formulary portion of total worldwide income to Washington.” WAC 458-20-194(3)(a).

3 No. 39496-4-III DISH Network, LLC v. Dep’t of Revenue

been calculating its B&O tax according to the separate accounting method, not the cost

apportionment formula.

DISH filed an administrative appeal, arguing that it remained entitled to use the

cost apportionment method. The Department’s Appeals Division agreed. See Clerk’s

Papers (CP) at 393-406 (Pl.’s Ex. 9) The Appeals Division determined DISH was entitled

to use the cost apportionment method as set forth in previous administrative decisions

and instructions. The May 2008 decision also stated DISH should utilize Rule 194, as

amended in 2006, to calculate future taxes. The decision included a statement that

DISH would receive further information from the Department’s Audit Division.

A few months later, in October 2008, the Department followed up on the Appeals

Division determination with an amended audit report for the tax period January 1 through

June 30, 2004. Attached to the amended audit report was Workpaper A, which showed

the Department’s line-by-line cost apportionment calculations. The audit report instructed

DISH to “[r]efer to apportionment Workpaper A for the cost apportionment detail.”

CP at 411 (Pl.’s Ex. 10 at 4). Workpaper A included an itemized list of “Total

Washington Expenses” to be included in the cost apportionment formula. Id. at 418

(Pl.’s Ex. 10 at 11). DISH’s programming costs were not included as expenses in the

4 No. 39496-4-III DISH Network, LLC v. Dep’t of Revenue

Workpaper A itemization. The amended audit report included a comment directing DISH

to contact the auditor or audit manager with any questions.

In July 2011, the Department conducted an audit of DISH’s excise tax returns

covering the four-year period of January 1, 2006 through December 31, 2009. The audit

concluded DISH failed to accurately report its B&O income by excluding its

programming costs from the apportionment formula. The audit claimed DISH owed

$9,325,106 in unpaid B&O taxes. The Department determined the total amount due,

which included penalties and interest, to be $11,959,168.

DISH again filed an administrative appeal. This time DISH lost. In its August

2012 written decision, the Appeals Division explained DISH should have been “using

the cost apportionment method required by the version of Rule 194 amended effective

2006.” Id. at 291 (Pl.’s Ex. 5 at 5). Under this method, programming costs should have

been included in the numerator of the cost ratio. The failure to include programming costs

in the calculation resulted in a smaller cost ratio and significant undercalculation of excise

tax liability. The Appeals Division upheld the Department’s assessment of outstanding

taxes, but modified a portion of the penalty. The revised total amount assessed to DISH

was $11,838,527.

5 No. 39496-4-III DISH Network, LLC v. Dep’t of Revenue

DISH paid the revised assessment under protest and then filed an action in

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