MAXA, J.
¶ 1 Bravern Residential II, LLC (Bravern) appeals the trial court's summary judgment order dismissing its refund action against the Department of Revenue (Department) for retail sales and business and occupation (B & O) taxes payable on construction services performed by one of its members, PCL Construction Services, Inc., (PCL) on property Bravern owned. Under WAC 458-20-170(2), a "speculative builder" — a contractor that builds on property...
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