City of Seattle v. State

In this appeal we hold that the City of Seattle is entitled to a refund or credit for excise taxes paid on revenue received from customers of its Department of Lighting, where such revenue was received exclusively for the cost of conversion from an overhead to an underground electric power distribution system.

The City of Seattle, through its Department of Lighting, “Seattle City Light,” engages in the business of furnishing electric power in Seattle and nearby areas. In most residential neighborhoods the electrical energy is supplied by means of an overhead distribution network. However, in…