Western Ag Land Partners v. Department of Revenue

The Department of Revenue appeals a Superior Court decision holding that a sale of certain center pivot irrigation equipment located on farm property is not subject to a retail sales tax because the equipment is a fixture on the realty. The Superior Court decision had reversed an administrative ruling by the Board of Tax Appeals. We affirm.

Western Ag Land Partners (WALP), a limited partnership, was formed in 1973 to acquire, lease and sell various parcels of irrigated farmland in Central Washington. The land was irrigated by center pivot irrigation systems (CPIS), which convey water through a…