Lendingtree, Llc v. Dept. Of Revenue

CourtCourt of Appeals of Washington
DecidedMarch 30, 2020
Docket80637-8
StatusPublished

This text of Lendingtree, Llc v. Dept. Of Revenue (Lendingtree, Llc 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
Lendingtree, Llc v. Dept. Of Revenue, (Wash. Ct. App. 2020).

Opinion

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

LENDINGTREE, LLC, ) No. 80637-8-I ) Appellant, ) ) v. ) ) PUBLISHED OPINION STATE OF WASHINGTON, ) DEPARTMENT OF REVENUE, ) ) Respondent. )

BOWMAN, J. — This case is about the application of the business and

occupation (B&O) tax statute and administrative rules for apportioning income

earned in Washington. The Washington State Department of Revenue (DOR)

and LendingTree LLC disagree as to where LendingTree’s customers, lenders

located across the country, receive the benefit of LendingTree’s services. We

agree with LendingTree that the benefit is received at the lender’s place of

business. Therefore, we reverse and remand for entry of judgment in favor of

LendingTree.

FACTS

LendingTree operates an online loan marketplace that matches

prospective borrowers with potential lenders. Through this marketplace, No. 80637-8-I/2

LendingTree “provides consumers a way to connect with multiple lenders for a

number of financial borrowing needs.” LendingTree allows lenders to “instantly

expand” their reach by connecting with LendingTree’s network of 30 million

borrowers and “high intent leads.”

On the LendingTree website, prospective borrowers can find educational

materials about the general loan process, varieties of loans, and tools to evaluate

the type and amount of credit they might want. Interested borrowers can

complete an online “Qualification Form” (QF) with their financial information and

the type of loan sought. Upon receipt of a completed QF, LendingTree analyzes

the data using proprietary software and refers the borrower to as many as five

potential lenders best suited to serve the borrower’s needs. The lenders

evaluate the referral and contact the borrower through LendingTree’s website.

These services are free to borrowers. Lenders pay LendingTree a “QF Match

Fee” for each referral, generally ranging from $4 to $100 depending on the type

and size of the loan involved and the borrower’s credit score. If a QF referral

results in a loan, the lender pays a “Closed Loan Fee” of $150 to $575 based on

the details of the loan.

LendingTree provides services for lenders located in the state of

Washington and reports income received from these customers for the purpose

of state B&O tax. DOR audited LendingTree for the period of January 1, 2010

through June 30, 2014. DOR concluded that LendingTree had not properly

attributed income to Washington during the audit period. Specifically, DOR

determined that LendingTree should have allocated its income based on the

2 No. 80637-8-I/3

location of potential borrowers rather than the lenders. As a result, DOR

assessed additional tax, interest, and penalties totaling $196,236.28. DOR’s

Administrative Review and Hearings Division upheld the audit findings.

LendingTree paid the assessment and filed a complaint for refund of the taxes,

interest, and penalties.

The parties filed cross motions for summary judgment. The parties

disputed the location of the benefit received by the lenders for the purpose of

apportioning B&O tax. The trial court concluded:

The service that LendingTree offers is to obtain qualification forms from consumers to present to consumers about LendingTree’s services and to have consumers seek loans from a pool of LendingTree’s clients, and this all happens where the consumer is located.

The trial court denied LendingTree’s motion, granted DOR’s motion for

summary judgment, and dismissed LendingTree’s complaint with prejudice.

LendingTree appeals.

ANALYSIS

LendingTree and DOR agree on the facts of this case. Indeed, “[b]y filing

cross motions for summary judgment, the parties concede there were no material

issues of fact.” Pleasant v. Regence BlueShield, 181 Wn. App. 252, 261, 325

P.3d 237 (2014). The appellate court reviews summary judgment decisions de

novo. Irwin Naturals v. Dep’t of Revenue, 195 Wn. App. 788, 793, 382 P.3d 689

(2016). The sole issue on appeal is the application of tax statutes to these

undisputed facts. This is an issue of law reviewed de novo. Wash. Imaging

Servs., LLC v. Dep’t of Revenue, 171 Wn.2d 548, 555, 252 P.3d 885 (2011).

3 No. 80637-8-I/4

LendingTree has the burden of proving DOR incorrectly assessed the tax and

establishing the correct amount of the tax. RCW 82.32.180.

A state cannot tax value earned outside its borders. ASARCO Inc. v.

Idaho State Tax Comm’n, 458 U.S. 307, 315, 102 S. Ct. 3103, 73 L. Ed. 2d 787

(1982). However, “by applying the principles of apportionment, states may tax

that part of an interstate transaction which takes place within the state.” Smith v.

State, 64 Wn.2d 323, 334, 391 P.2d 718 (1964). This concept of apportionment

applies to Washington’s B&O tax imposed “for the act or privilege of engaging in

business activities” in this state. RCW 82.04.220(1). Any person earning income

taxable in Washington and in another state must apportion to Washington the

income derived from business activities performed within this state. RCW

82.04.460(1).

In 2010, the Washington legislature adopted a “single factor” receipts

apportionment scheme for service income. LAWS OF 2010, 1st Spec. Sess., ch.

23; RCW 82.04.460, .462; WAC 458-20-19402. Under this method, the taxpayer

multiplies its “apportionable income,” or gross income, by the “receipts factor.”

RCW 82.04.462(1), .460(4)(a). The “receipts factor” is a fraction, calculated as

follows:

The numerator of the receipts factor is the total gross income of the business of the taxpayer attributable to this state during the tax year from engaging in an apportionable activity. The denominator of the receipts factor is the total gross income of the business of the taxpayer from engaging in an apportionable activity everywhere in the world during the tax year.

RCW 82.04.462(2), (3)(a).

4 No. 80637-8-I/5

To compute the receipts factor, gross income of the business generated

from each apportionable activity is attributed to the state “[w]here the customer

received the benefit of the taxpayer’s service.” RCW 82.04.462(3)(b)(i). For a

service-related business like LendingTree, “the benefit is received where the

customer’s related business activities occur.” WAC 458-20-19402(303)(c).1

DOR defines the “customer’s related business activity” as “the customer

business activity that most closely or directly relates to the services performed by

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Related

ASARCO Inc. v. Idaho State Tax Commission
458 U.S. 307 (Supreme Court, 1982)
Smith v. State
391 P.2d 718 (Washington Supreme Court, 1964)
Imaging Services v. State Dept. of Revenue
252 P.3d 885 (Washington Supreme Court, 2011)
Irwin Naturals, V State Of Wa Dept Of Revenue
382 P.3d 689 (Court of Appeals of Washington, 2016)
Washington Imaging Services, LLC v. Department of Revenue
171 Wash. 2d 548 (Washington Supreme Court, 2011)
Pleasant v. Regence BlueShield
325 P.3d 237 (Court of Appeals of Washington, 2014)

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