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CLIFFORD v. STATE

No. 40666.

78 Wn.2d 4 (1970)

469 P.2d 549

RICHARD A. CLIFFORD et al., Appellants, v. THE STATE OF WASHINGTON, Respondent. RICHARD A. CLIFFORD et al., Appellants, v. THE STATE OF WASHINGTON, Respondent.

The Supreme Court of Washington, En Banc.

May 14, 1970.

Attorney(s) appearing for the Case

Preston, Thorgrimson, Horowitz, Starin & Ellis, by Charles Horowitz, and Preston, Thorgrimson, Starin, Ellis & Holman, by Edward Starin, for appellants.

The Attorney General, Henry W. Wager and Timothy R. Malone, Assistants, for respondent.

ROSELLINI, J.

In these consolidated cases, the superior court upheld a ruling by the Washington State Department of Revenue that interest received by the appellants under installment contracts for the sale of real estate was taxable as a part of the gross income of their business of subdividing and selling real estate.

The appeal is prosecuted upon three contentions, the first being that interest received by the sellers of real estate is exempt from the business...

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