Legal Opinion

Fidelity Title Co. v. Department of Revenue

Court of Appeals of Washington

Decided November 17, 1987No. 9939-0-IIPublishedCited by 11 opinions

1Opinion of the CourtWorswick, J.

The Department of Revenue appeals a superior court determination that Fidelity Title Company should be classified, for business and occupation tax purposes, as an abstract, title insurance and escrow business (WAC 458-20-156) instead of as an insurance agent (WAC 458-20-164). The latter classification would result in a tax more than twice as much as would the former. We affirm.

This litigation began when the Department assessed Fidelity for a deficiency following an audit. Fidelity paid the tax and appealed directly to the Superior Court pursuant to RCW 82.32.180, rather than to the Board of…

2Cases cited6 opinions

  1. Time Oil Co. v. StateWashington Supreme Court · 1971
  2. Sonitrol Northwest, Inc. v. City of SeattleWashington Supreme Court · 1974
  3. Crown Zellerbach Corp. v. StateWashington Supreme Court · 1954
  4. Coast Pacific Trading, Inc. v. Department of RevenueWashington Supreme Court · 1986
  5. Downtown Traffic Planning Committee v. RoyerCourt of Appeals of Washington · 1980

1 more not listed; retrieve them via the Exa API.

3Cited by11 opinions

  1. Association of Washington Business v. Department of RevenueWashington Supreme Court · 2005
  2. GMAC Mortgage, LLC v. First American Title InsuranceMassachusetts Supreme Judicial Court · 2013
  3. First American Title Insurance v. Department of RevenueWashington Supreme Court · 2001
  4. Safeway, Inc. v. Deparment of RevenueCourt of Appeals of Washington · 1999
  5. Safeway, Inc. v. Department of RevenueCourt of Appeals of Washington · 1999

6 more not listed; retrieve them via the Exa API.

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