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FIRST STUDENT, INC. v. STATE, DEPARTMENT OF REVENUE

No. 96694-0.

451 P.3d 1094 (2019)

FIRST STUDENT, INC., Petitioner, v. State of Washington, DEPARTMENT OF REVENUE, Respondent.

Supreme Court of Washington.

Filed November 14, 2019.

Attorney(s) appearing for the Case

Brett S. Durbin , Lane Powell PC, 1420 5th Avenue, Suite 4200, Seattle, WA 98101-2375, for Petitioner.

Cameron Gordon Comfort , Jessica E. Fogel , Attorney General's Office/Revenue Division, P.O. Box 40123, Olympia, WA 98504-0123, Olympia, WA 98504-0123 for Respondent.

Brett S. Durbin , Lane Powell PC, 1420 5th Avenue, Suite 4200, Seattle, WA 98101-2375, for Amicus Curiae (Durham School Services LP).

Robert Lee Mahon, III , Erin Earl , Perkins Coie LLP, 1201 3rd Avenue, Suite 4900, Seattle, WA 98101-3095, for Amicus Curiae (National Association for Pupil Transportation).

¶1 This case involves an issue of statutory interpretation regarding the applicability of a tax classification. First Student Inc., a school bus contractor, seeks reversal of a Court of Appeals decision affirming a summary judgment dismissal of its business and occupation (B & O) tax refund action. At issue is whether First...

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