Shurgard Mini-Storage of Tumwater v. Department of Revenue

In a consolidated trial, the Superior Court entered a judgment in favor of a number of operators of mini-storage warehouse facilities for a refund of public utility taxes and interest paid under protest for the audit period beginning January 1, 1976, and ending December 31, 1980. The trial court concluded that the relationship of the various operators and their customers was that of landlord and tenant rather than bailor and bailee, and consequently the tax imposed on the amount of rentals received was a tax on property in violation of the uniformity requirement of article 7, section 1 of the…