Royal Oaks Country Club v. Dep't of Revenue

CourtWashington Supreme Court
DecidedJanuary 11, 2024
Docket101,770-7
StatusPublished

This text of Royal Oaks Country Club v. Dep't of Revenue (Royal Oaks Country Club v. Dep't of Revenue) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Royal Oaks Country Club v. Dep't of Revenue, (Wash. 2024).

Opinion

FILE THIS OPINION WAS FILED FOR RECORD AT 8 A.M. ON JANUARY 11, 2024 IN CLERK’S OFFICE SUPREME COURT, STATE OF WASHINGTON JANUARY 11, 2024 ERIN L. LENNON SUPREME COURT CLERK

IN THE SUPREME COURT OF THE STATE OF WASHINGTON

ROYAL OAKS COUNTRY CLUB, a ) Washington nonprofit corporation, ) No. 101770-7 ) Respondent, ) ) v. ) En Banc ) STATE OF WASHINGTON, DEPARTMENT ) OF REVENUE, ) ) Petitioner. ) Filed: January 11, 2024 ________________________________________)

MADSEN, J.—RCW 82.04.4282 permits taxpayers to deduct from their business

and occupation (B&O) tax “bona fide” initiation fees and dues, among other things.

Dues in exchange for or graduated on receipt of goods and services cannot be deducted.

RCW 82.04.4282. Royal Oaks Country Club sought to deduct its initiation fees pursuant

to this provision. New members are admitted to the club based on a one-time initiation

fee, which varies based on membership level. Prior to using any of Royal Oaks’ dining

services or golfing, swimming, or fitness facilities, members must pay both their

initiation fee and first month’s dues. Because the initiation fee alone does not No. 101770-7

automatically entitle a member to use any service or facility, the fee is paid solely for the

privilege of membership. The Court of Appeals held Royal Oaks’ fee qualifies as a bona

fide initiation fee and is therefore wholly deductible. We affirm.

BACKGROUND 1

Royal Oaks is a nonprofit corporation that owns and operates a country club in

Vancouver, Washington. Royal Oaks maintains a golf course with accompanying

practice ranges and a retail shop, as well as swimming facilities, a clubhouse with four

primary dining areas, other bars and dining spaces, and a fitness center.

Royal Oaks offers individual and corporate memberships at different levels. The

most expensive memberships are “proprietary,” “corporate,” and “intermediate.”

Proprietary members may access all services and facilities; they can serve as directors

and officers and vote in elections for these offices; proprietary membership may be

transferred to another person in a member’s immediate family; and resignation of a

proprietary membership may yield a “refund equity.” Clerk’s Papers (CP) at 46-47.

Similarly, corporate members may access all facilities and services. Intermediate

members may also access all of Royal Oaks’ facilities and services. Intermediate

members pay half dues until reaching a certain age, at which point their membership is

converted to proprietary. These members cannot vote for or serve as directors or officers,

and their memberships are not transferrable.

1 Unless otherwise noted, Royal Oaks stipulated to the facts contained in this section. The facts are not disputed here.

2 No. 101770-7

“Social with golf” members have limited access to golfing facilities but have full

access to the fitness center, swimming facilities, dining, and social events. CP at 47.

These members are allowed one round of golf monthly and on that day may access

golfing facilities and services. They may purchase additional rounds of golf from winter

to spring by paying green fees. Like intermediate members, social with golf members

cannot participate in elections or governance of the club. “Social” members cannot use

the golf course or practice facilities but have unlimited access to the other facilities. Id.

Social members cannot participate in club governance.

Finally, “dining” members cannot access the golf course, golf-related practice

facilities, or the swimming and fitness centers. Dining members have unlimited access to

the dining services. Like social with golf and social members, dining members cannot

participate in club governance.

New members must pay a one-time initiation fee. The fee is due along with the

application for membership. Members must pay the initiation fee and their first month’s

dues before accessing any facility, service, or social event at Royal Oaks. Nonmember

guests must pay “green fees” to access the golf course and other golfing facilities. CP at

100.

Initiation fees are tied to membership level, as are monthly dues. Members

received monthly statements of accounts that included their monthly dues and other debts

(e.g., green fees and dining charges). If a member was more than 60 days late in

payment, Royal Oaks suspended all member privileges until payment was made.

3 No. 101770-7

Royal Oaks had not historically sought a deduction for bona fide initiation fees. In

2014, it claimed the deduction. This led to an audit for the 2011-2016 tax period. The

auditor divided Royal Oaks’ income accounts into three categories: dues, retail, and

service. The auditor placed the one-time initiation fees, monthly dues, and other types of

income into the dues category and then calculated the deductible percentage of bona fide

dues at approximately 65 percent. This percentage was derived from former Rule 183’s

“cost of production” method. 2 The parties stipulated that the Washington State

Department of Revenue (DOR) assessed $2,640 in retail B&O tax and $45,245 in retail

sales tax on Royal Oaks’ initiation fee receipts for the tax period.

Royal Oaks sought administrative review of the assessment, arguing the initiation

fees were “solely capital contributions” and therefore completely deductible under RCW

82.04.4282. CP at 106. Noting that Royal Oaks failed to provide any contractual or

bylaw language “indicating the nature of its initiation fees,” the hearing examiner denied

the initiation fee argument and affirmed the audit. Id. at 109.

On reconsideration, Royal Oaks provided documentation on its initiation fees.

According to Royal Oaks, this documentation showed the fees were purely for entry and

thus fully deductible. The tax review officer concluded the documentation did not

2 This calculation method is discussed in the auditor’s ruling. CP at 107, 113. Washington State Department of Revenue applies this calculation to taxpayers who do not “segregate the portion of their initiation fees (or dues . . .) attributable to providing the privilege of membership from the portion attributable to providing taxable goods and services.” Pet. for Rev. at 6; former WAC 458-20-183(4)(c)(ii) (1995) (in effect during the relevant taking period 2011-2016). The cost of production method was repealed shortly after Royal Oaks’ audit. The repeal did not affect the outcome of Royal Oaks’ case. Nor is it disputed here.

4 No. 101770-7

describe whether the fees were considered solely capital contributions or if the fees

entitled new members to goods and services, and denied reconsideration.

Royal Oaks paid the tax assessment and filed a refund action in superior court.

Royal Oaks maintained that the initiation fees were statutorily deductible. The parties

filed cross motions for summary judgment. The court granted DOR’s motion and denied

Royal Oaks’ motion, ruling the initiation fees were only partially deductible.

The Court of Appeals held the initiation fees were wholly deductible based on

RCW 82.04.4282 and reversed the superior court’s grant of summary judgment. Royal

Oaks Country Club v.

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

Related

Folsom v. Burger King
958 P.2d 301 (Washington Supreme Court, 1998)
Boeing Co. v. Aetna Casualty & Surety Co.
784 P.2d 507 (Washington Supreme Court, 1990)
Imaging Services v. State Dept. of Revenue
252 P.3d 885 (Washington Supreme Court, 2011)
Red Cedar Shingle Bureau v. State
382 P.2d 503 (Washington Supreme Court, 1963)
Automobile Club v. Department of Revenue
621 P.2d 760 (Court of Appeals of Washington, 1980)
State, Dept. of Ecology v. Campbell & Gwinn
43 P.3d 4 (Washington Supreme Court, 2002)
Department v. Granger
153 P.3d 839 (Washington Supreme Court, 2007)
Folsom v. Burger King
135 Wash. 2d 658 (Washington Supreme Court, 1998)
Department of Ecology v. Campbell & Gwinn, L.L.C.
146 Wash. 2d 1 (Washington Supreme Court, 2002)
Department of Labor & Industries v. Granger
159 Wash. 2d 752 (Washington Supreme Court, 2007)
Densley v. Department of Retirement Systems
162 Wash. 2d 210 (Washington Supreme Court, 2007)
Washington Imaging Services, LLC v. Department of Revenue
171 Wash. 2d 548 (Washington Supreme Court, 2011)
Scrivener v. Clark College
334 P.3d 541 (Washington Supreme Court, 2014)
Keck v. Collins
357 P.3d 1080 (Washington Supreme Court, 2015)
Avnet, Inc. v. Department of Revenue
384 P.3d 571 (Washington Supreme Court, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
Royal Oaks Country Club v. Dep't of Revenue, Counsel Stack Legal Research, https://law.counselstack.com/opinion/royal-oaks-country-club-v-dept-of-revenue-wash-2024.