PART PUBLISHED OPINION
ARMSTRONG, C.J.
Lacey Nursing Center, Inc., Olympic Health Services, Inc., and Sherwood Manor, Inc. (Taxpayers) are for-profit nursing homes that seek refunds of business and occupation taxes for the period 1989 through 1992. Taxpayers claim an exemption from B & O taxes for that portion of their revenue derived from the lease of rooms to residents. This claim is based on the sale-of-real-estate exemption under RCW 82.04.390 and...
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