Booker Auction Co. v. Department of Revenue

¶1 This appeal involves the Department of Revenue’s (Department) instruction to Booker Auction Company to pay excise tax on farm equipment sold at its future auctions. Booker’s eventual superior court appeal was dismissed when the court reasoned it lacked subject matter jurisdiction to hear the appeal because no taxes had been improperly paid to trigger the court’s jurisdiction. Booker now contends (1) it is entitled to review under the Administrative Procedure Act (APA), chapter 34.05 RCW, and (2) RCW 82.32.180 (requiring an aggrieved taxpayer to appeal to the superior court of Thurston…