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DOT FOODS, INC. v. DEPARTMENT OF REVENUE, STATE

No. 35733-0-II.

173 P.3d 309 (2007)

DOT FOODS, INC., Appellant, v. DEPARTMENT OF REVENUE, State of Washington, Respondent.

Court of Appeals of Washington, Division 2.

November 27, 2007.

Attorney(s) appearing for the Case

Jacquelyn A. Beatty, Attorney at Law, Howard Mark Goodfriend, Edwards Sieh Smith & Goodfriend PS, Seattle, WA, for Appellant.

Cameron Gordon Comfort, Atty. Gen. Office, Olympia, WA, for Respondent.

PENOYAR, J.

¶ 1 Dot Foods sought a refund of business and occupation (B & O) taxes paid between 2000 and 2006, claiming that the Department of Revenue (Department) improperly denied them an exemption. During this time period, Dot Foods produced food products out-of-state that it sold (through a wholly-owned subsidiary) to dairies, meat packers, and other food processors located in Washington, who then used the products as ingredients in other products that...

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