Department of Revenue v. Wheeler

HENRY C. BREITHAUPT, Judge.

I. INTRODUCTION

This matter, involving the 2000 tax year, is before the court on a stipulated record and cross-motions for summary judgment. As to the factual basis for an outcome, the parties each argue that the other has the burden of proof. The court does not need to decide that issue because Defendants (taxpayers) have met the burden of proof, assuming it was theirs.

II. FACTS

Taxpayers are and, at all times material for this case, were residents of the State of Washington. For most of his career, Barney Wheeler (Wheeler) was employed by Fort James Corporation…