St. Joseph General Hospital v. Department of Revenue

¶1 St. Joseph General Hospital (St. Joseph or hospital) appeals from a Board of Tax Appeals (Board) order requiring it to pay business and occupation (B&O) tax pursuant to RCW 82.04.220 for amounts (1) received from Medicare beneficiaries1 and their secondary insurers (Medigap insurers) for patient copayments and deductibles and (2) the hospital paid to an emergency room physician organization. The hospital argues that, under the plain language of former RCW 82.04.4297 (1988), Medicare beneficiaries and Medigap insurers act as instrumentalities of the United States when they pay patient…