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IN RE ESTATE OF HAMBLETON

Nos. 89419-1, 89500-7.

335 P.3d 398 (2014)

In re the Matter of the ESTATE OF Helen M. HAMBLETON, Deceased, Steve Hambleton, in his capacity as personal representative of the Estate of Helen M. Hambleton, Respondent, v. State of Washington, Department of Revenue, Appellant. In re the Matter of the Estate of Jessie Campbell MacBride, Deceased, Thomas A. MacBride III and Philip MacBride, Personal Representatives of the Estate of Jessie Campbell Macbride, Appellants, v. State of Washington, Department of Revenue, Respondent.

Supreme Court of Washington, En Banc.

October 2, 2014.

Attorney(s) appearing for the Case

David M. Hankins , Charles E. Zalesky , Attorney General of Washington, Olympia, WA, Rhys Matthew Farren , Davis Wright Tremaine LLP, Bellevue, WA, Dirk Jay Giseburt , Richard Alan Klobucher , Roger Ashley Leishman , Davis Wright Tremaine LLP, Seattle, WA, for Appellant.

Thomas M. Culbertson , Attorney at Law, Laura J. Black , Lukins & Annis, P.S., Spokane, WA, David M. Hankins , Atty Generals Ofc/Revenue Division, Charles E. Zalesky , Attorney General of Washington, Olympia, WA, for Respondent.

Seth Leslie Cooper , Newton Kight LLP, Thomas L. Cooper , Attorney at Law, Everett, WA, for Amicus Curiae on behalf of Doris H. McInniis Qtip Trust.

Howard Mark Goodfriend , Smith Goodfriend PS, Seattle, WA, for Amicus Curiae on behalf of Dot Foods, Inc.

WIGGINS, J.

¶ 1 In 2013, the legislature amended the Estate and Transfer Tax Act, chapter 83.100 RCW, in response to our decision in In re Estate of Bracken, 175 Wn.2d 549, 290 P.3d 99 (2012), in which we narrowly construed the term "transfer." The amendment allows the Department of Revenue (DOR) to tax qualified terminable interest property...

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