Cities and towns

From the 2024 DOR Tax Exemption Study

Det. No. 12-0102, 32 WTD 250 (October 29, 2013) 254 The Supreme Court of Washington has addressed the unique application of Rule 111 to client reimbursements to lawyers, for advances made to third party providers in Christensen, O'Connor, Garrison & Havelka v. Dep't of Revenue, 97 Wn.2d 764, 769, 649 P.2d 839 (1982), and Walthew, Warner, Keefe, Arron, Costello & Thompson v. Dep't of Revenue, 103 Wn.2d 183, 188, 691 P.2d 559 (1984). Christensen concerned payments made by a law firm to attorneys in another city on behalf of the client. The parties stipulated that the out of town attorneys understood they were working directly for the clients. The court held that the requirements for exclusion under Rule 111 were satisfied. In Walthew, a law firm specializing in worker’s compensation and personal injury cases followed a practice of signing contracts with its clients confirming the client’s obligation to pay all court costs, medical, or other expenses involved in litigation. The firm customarily paid those expenses and then sought reimbursement from the clients. The court stated: The language of Rule 111 is consistent with [RCW 82.04.290] if it is read to reflect the statute’s obvious