Nordstrom Credit, Inc. v. Department of Revenue

Appellant Nordstrom Credit, Inc. (Credit) challenges the trial court's ruling that it may not apportion the income at issue among various states for purposes of calculating the Washington business and occupation (B&O) tax. In 1988, the Department of Revenue (DOR) assessed a deficiency of $881,441 against Credit for the years 1984 through 1987. Credit paid the deficiency and brought a refund action under RCW 82.32.180.

Credit was formed to finance the accounts receivable of its parent corporation, Nordstrom, Inc. (Nordstrom). In October 1984, Nordstrom and Credit executed two agreements under…