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ESTATE OF HEMPHILL v. STATE, DEPT. OF REVENUE (ESTATE TAX)

No. 74974-4.

105 P.3d 391 (2005)

153 Wash.2d 544

ESTATE OF Wylie M. HEMPHILL, by its personal representative, Thomas W. Hemphill; Estate of Wyoma G. Shea, by its personal representative, Barbara Sauerbrey; and Estate of Morgan J. O'Brien by its co-personal representative, Nancy O'Brien, Appellants, v. STATE of Washington, DEPARTMENT OF REVENUE (ESTATE TAX); and WIlliam Rice, its acting chief executive officer, Respondents.

Supreme Court of Washington, En Banc.

Decided February 3, 2005.

Attorney(s) appearing for the Case

Raymond Huber Siderius, Charles Richard Lonergan, William Emmett Wall, Siderius Lonergan & Martin LLP, G. Lawrence Salkield, Orly J. Sorrel, Seattle, for Appellants.

Donald F. Cofer, Debra Ellen Casparian, Olympia, for Respondents.

Gary C. Randall, Richard Patrick Algeo, Spokane, for Amicus Curiae National Federation of Independent Business and Wash. State Farm Bureau Federation.

C. JOHNSON, J.

This case involves a challenge to the validity of the Department of Revenue's assessment and calculation of estate taxes, under chapter 83.100 RCW. The estates of Wylie M. Hemphill, Thomas W. Hemphill, Wyoma G. Shea, Barbara Sauerbrey, Morgan J. O'Brien and Nancy O'Brien, through their personal representatives (Appellants), represent, in a class action, those appealing a Thurston County Superior Court cross-motion summary judgment order dismissing their...

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