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SIMPSON INV. CO. v. STATE, DEPT. OF REVENUE

No. 67630-5.

3 P.3d 741 (2000)

141 Wash.2d 139

SIMPSON INVESTMENT COMPANY, Respondent, v. STATE of Washington, DEPARTMENT OF REVENUE, Petitioner.

Supreme Court of Washington, En Banc.

July 13, 2000.

Attorney(s) appearing for the Case

Christine Gregoire, Atty. Gen., John S. Barnes, Asst. Atty. Gen., Olympia, for Petitioner.

Lane, Powell, Spears & Lubersky, George Carl Mastrodonato, Kathleen Dell Benedict, Olympia, Michael Barr King, Seattle, for Respondent.

Davis, Wright, Tremaine, Garry George Fujita, Seattle, for Amicus Curiae on Behalf of Association of Washington Businesses.

MADSEN, J.

This dispute between Simpson Investment Company (Simpson) and the State Department of Revenue (Department) presents the question of whether Simpson, a holding corporation for multiple subsidiaries, is a "financial business" for purposes of RCW 82.04.4281 (section 4281). Section 4281 provides a Business and Occupational (B & O) tax deduction for the investment income of all persons not "engaging in banking, loan, security, or other financial businesses...

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