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RHO COMPANY v. DEPARTMENT OF REVENUE

No. 55569-9.

113 Wn.2d 561 (1989)

782 P.2d 986

RHO COMPANY, INC., Respondent, v. THE DEPARTMENT OF REVENUE, Petitioner.

The Supreme Court of Washington, En Banc.

October 31, 1989.

Attorney(s) appearing for the Case

Kenneth O. Eikenberry, Attorney General, and Mary E. Fairhurst, Assistant, for petitioner.

Joseph D. Holmes, Jr., and Philip A. Talmadge (of Karr, Tuttle, Campbell), for respondent.

DURHAM, J.

Rho Company, Inc. (Rho) contends that WAC 458-20-111 — which excludes certain "pass through" payments from gross income for purposes of business and occupation taxes — applies to its business, which supplied temporary engineering personnel to client companies. Rho regularly received payments from its clients that it then passed on to the temporary personnel as wages, per diem and repayment of travel...

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