McDonnell & McDonnell v. State

The taxpayers, respondents in these consolidated causes, have challenged the action of the State Tax Commission in imposing a business and occupation tax *554respecting manufacturing activity as defined in RCW 82.04-.120, and have petitioned for a refund of taxes paid thereunder.

The State Tax Commission has taken the position that the preparation or processing of dried split peas by the taxpayers comes within the scope of the definition of “manufacturing activity,” as set forth in the aforementioned statute. The trial judge sustained the taxpayers’ contentions that their activities did not…