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COAST PACIFIC TRADING, INC. v. DEPARTMENT OF REV.

No. 52158-1.

105 Wn.2d 912 (1986)

719 P.2d 541

COAST PACIFIC TRADING, INC., ET AL, Appellants, v. THE DEPARTMENT OF REVENUE, Respondent.

The Supreme Court of Washington, En Banc.

May 22, 1986.

Attorney(s) appearing for the Case

Bell & Ingram, P.S., William F. Ingram, and David S. Carson, for appellants.

Kenneth O. Eikenberry, Attorney General, and James R. Tuttle, Assistant, for respondent.

Ray Graves and L. Paul Alvestad on behalf of Manke Lumber Co.; John T. Piper and Franklin G. Dinces on behalf of Longview Fibre Co., amici curiae for appellants.

UTTER, J.

Coast Pacific Export, Inc., and Coast Pacific Trading, Inc., seek immunity from Washington's business and occupation tax for certain sales of timber to foreign customers. The corporations claim they fall within a Department of Revenue regulation, WAC 458-20-193C, that defines a tax exemption for export sales. However, the trial court ruled that the corporations' sales do not qualify for the exemption of Rule 193C. We affirm the trial court's decision.

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