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WELLS FARGO BANK v. DEPARTMENT OF REVENUE

No. 40923-2-II.

271 P.3d 268 (2012)

166 Wn. App. 342

WELLS FARGO BANK, N.A., Appellant, v. DEPARTMENT OF REVENUE, State of Washington, Respondent. Wells Fargo Bank, N.A., Appellant/Cross Respondent, v. Department of Revenue, State of Washington, Respondent/Cross Appellant.

Court of Appeals of Washington, Division 2.

February 1, 2012.

Attorney(s) appearing for the Case

Michele G. Radosevich , Dirk Jay Giseburt , Davis Wright Tremaine LLP, Seattle, WA, for Appellant/Cross-Respondent.

Rosann Fitzpatrick , Washington Attorney General, Olympia, WA, for Respondent/Cross-Appellant.

VAN DEREN, J.

¶ 1 Wells Fargo Bank, N.A., appeals from the superior court's order denying its summary judgment motion and granting summary judgment to the Washington State Department of Revenue (DOR). Wells Fargo contends that: (1) RCW 82.32.060(4) required payment of interest on a refund arising from settlement of a tax dispute through a closing agreement with DOR; and (2) Wells Fargo did not waive its statutory right to interest in entering the closing agreement...

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