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FIDELITY TITLE CO. v. DEPT. OF REVENUE

No. 9939-0-II.

49 Wn. App. 662 (1987)

745 P.2d 530

FIDELITY TITLE COMPANY, Respondent, v. THE DEPARTMENT OF REVENUE, Appellant.

The Court of Appeals of Washington, Division Two.

November 17, 1987.

Attorney(s) appearing for the Case

Kenneth O. Eikenberry, Attorney General, and John M. Gray, Assistant, for appellant.

William L. Weigand, Jr., Richard M. Wilson, and Lyon, Beaulaurier, Weigand, Suko & Gustafson, for respondent.

WORSWICK, J.

The Department of Revenue appeals a superior court determination that Fidelity Title Company should be classified, for business and occupation tax purposes, as an abstract, title insurance and escrow business (WAC 458-20-156) instead of as an insurance agent (WAC 458-20-164). The latter classification would result in a tax more than twice as much as would the former. We affirm.

This litigation began when the Department assessed Fidelity for a...

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