Valley Fruit v. Department of Revenue

Valley Fruit and Douglas Fruit applied for a sales and use tax exemption. The Department of Revenue denied both applications; the Board of Tax Appeals upheld the denials. In separate actions, the Yakima County Superior Court and the Franklin County Superior Court reversed the Board of Tax Appeals and granted summary judgment in favor of the fruit companies. The Department of Revenue appeals. We affirm.

Douglas Fruit and Valley Fruit (referred to as the “fruit companies”) constructed apple packing and storage facilities. The apple packing process begins with whole, edible apples which are…