City of Spokane ex rel. Wastewater Management Department v. Department of Revenue

The Department of Revenue (Department) *256taxes revenue obtained from “sewerage collection” services at a higher rate than revenue attributable to sewage “transfer” functions. The City of Spokane Sewer Department (City) asked the Department for a refund, arguing more of its sewer system is engaged in transfer functions. A Department administrative law judge rejected the request. The Board of Tax Appeals affirmed. The superior court reversed the Board. The Department appeals. We reverse the superior court and affirm the Department’s decision.

FACTS

In 1993, the City’s Sewer Department managed…