City of Puyallup v. Pacific Northwest Bell Telephone Co.

(dissenting)—The trial court ruled that the increased 1980 business and occupation tax (B & 0 tax) against Pacific Northwest Bell Telephone Company (PNB) and Washington Natural Gas Company (WNG) had been constitutionally assessed. The majority now reverses the trial court's decision, holding that provisions of the 1980 tax ordinance were ambiguous and were retroactively applied to 1979 revenues. The majority holds that such B & 0 taxes can be applied only to 1980 revenues, and that the City of Puyallup is prohibited from taxing any company revenues for the 1979 calendar year.

I believe the…