Avnet, Inc. v. Department of Revenue

¶40 Washington’s business and occupation (B&O) tax falls on wholesalers “for *69the act or privilege of engaging in business activities” inside our state. RCW 82.04.220(1). The lead opinion upholds the imposition of this tax on two categories of sales that, in this case, were indisputably made by Avnet outside our state: national sales and third party drop-shipped sales. It rejects Avnet’s arguments that the tax on those interstate sales fell outside the reach of RCW 82.04.220, was impermissible under former WAC 458-20-193 (1992) (Rule 193), and violated the dormant commerce clause, U.S. Const,…