Washington Imaging Services, LLC v. Department of Revenue

¶1 Washington Imaging Services LLC (WIS) appeals the trial court’s grant of summary judgment in favor of the state Department of Revenue (DOR). The trial court found the funds that WIS collects from its patients or its patients’ insurance companies and forwards to Overlake Imaging Associates PC are gross income to WIS and subject to Washington’s business and *284occupation (B&O) tax. We hold that these funds are payments WIS collects much like a collection agency for services that Overlake renders and, as such, are not gross income to WIS’ business and are not subject to Washington’s B&O tax.…