HomeStreet, Inc. v. Department of Revenue

¶1 — HomeStreet, Inc., sued the Department of Revenue (DOR) for a refund of business and occupation (B&O) taxes it alleged that it had overpaid. This case of first impression requires that we address whether RCW 82.04.4292 allows a lender to deduct, as “amounts derived from interest received,” service fees it earned on qualifying home loans it originated and then sold on the *830secondary market under agreements that required loan servicing.1 If RCW 82.04.4292 allows the deductions for income from qualifying loans HomeStreet services but no longer owns, then it overpaid. We hold that when…