Clark County Public Utility District No. 1 v. Department of Revenue

¶1 The Department of Revenue (Department) appeals from a summary judgment for partial refunds to two public utility districts for privilege taxes imposed under RCW 54.28.020. Clark County Public Utility District No. 1 and Grays Harbor Public Utility District No. 1 (Districts) cross-appealed from the summary judgment that refunded only three years of taxes, not five. We hold that because the tax is imposed “for the act or privilege of engaging within this state in the business of operating works, plants or facilities for the generation, distribution *741and sale of electric energy,”1 RCW…