Wash. Court of Appeals published opinion — D2 60254-7-II Published Opinion.pdf

Citation: Wash. Court of Appeals published opinion — D2 60254-7-II Published Opinion.pdf
Jurisdiction: Washington (state)
Source: Official source
Original Source: https://www.courts.wa.gov/opinions/pdf/D2%2060254-7-II%20Published%20Opinion.pdf ↗

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were paid directly from the operating accounts, and not first transferred to AMC, is of no moment.

Indeed, AMC does not point to any authority suggesting—nor does RCW 82.04.080 specify—

such a requirement. Thus, because the onsite employee wages are part of the value proceeding or

accruing from AMC’s business, AMC’s argument fails.

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No. 60254-7-II

AMC also argues the Department’s alleged imputation of income violates due process

because it amounts to compelling one taxpayer to pay tax on another taxpayer’s property. For the

reasons discussed above, the Department did not impute income to AMC. Because the Department

did not impute income, there is no violation of due process.

CONCLUSION

We hold that the superior court did not err when it denied AMC’s motion for summary

judgment and granted summary judgment in favor of the Department. Accordingly, we affirm the

superior court.

A majority of the panel having determined that this opinion will not be printed in the

Washington Appellate Reports but will be filed for public record in accordance with RCW 2.06.040,

it is so ordered.

Lee, P.J.
We concur:

Glasgow, J.

Che, J.

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