Clifford v. State

In these consolidated cases, the superior court upheld a ruling by the Washington State Department of Revenue that interest received by the appellants under installment contracts for the sale of real estate was taxable as a part of the gross income of their business of subdividing and selling real estate.

The appeal is prosecuted upon three contentions, the first being that interest received by the sellers of real estate is exempt from the business and occupation tax imposed under RCW 82.04.290 upon

every person engaging ... in any business activity other than or in addition to those enumerated…