Longview Fibre Co. v. Cowlitz County

Cowlitz County appeals a summary judgment requiring it to refund $84,456.45 in taxes plus interest to Longview Fibre Company. This case presents the following issue: When the taxpayer, who pays its property taxes in semiannual installments, deems its taxes, or any part thereof, excessive, must each installment be paid under protest to preserve the right to a refund of the excessive tax? We conclude that each installment must be paid under protest to preserve the right to a complete refund of an overpayment. Therefore, we reverse the Superior Court.

This case arose from a valuation dispute…