Bowie v. Department of Revenue

¶1 Richard and Annette Bowie, d/b/a Valpak of Western Washington—North, as franchisees of Valpak Direct Marketing Systems, Inc., create and distribute advertising coupon mailings to Washington residential addresses. The Department of Revenue (DOR), at their request, categorized this activity as "publishing” and taxed *19them under the business and occupations (B&O) tax rate applicable to persons engaged in the publishing business. The DOR later rescinded this decision. The Bowies and other Valpak Marketing franchisees (Taxpayers)1 sought superior court review of the rescission. In ruling on…