Property Holding & Development, Inc. v. Department of Employment Security

Property Holding and Development, Inc. (hereafter PHD), appeals an adverse ruling by the Superior Court for Pierce County upholding an assessment for employment taxes levied on commissions paid to its salesmen. The superior court decision affirmed an administrative ruling by a hearing examiner for the Employment Security Department (hereafter Department), entered following a hearing and subsequently affirmed by the Employment Security Commissioner. The pivotal issue on appeal presents a question of first impression in this state. That issue is whether the selling of “units” in limited…