Rusan's, Inc. v. State

(dissenting) — I dissent. I agree with the majority that the test in the disposition of this case is whether the handling of the goods by Rusan’s was essentially comparable to a wholesaling function. The intent clause of RCW 82.04.270(2) clearly indicates that the legislative purpose is to impose a tax upon activities that would otherwise constitute a wholesaling function except for a sale of the goods taking place. The statute provides in part:(2) The tax imposed by this section is levied and shall be collected from every person engaged in the business of distributing in this state articles…