In addition to federal tax controversies, Colvin + Hallett also represents clients in controversies with Washington State agencies, including the Department of Revenue, the Employment Security Department, and the Department of Labor & Industries. Our attorneys possess extensive experience with the specific appeals processes of these agencies, as well as a unique depth of knowledge concerning Washington State tax law. In fact, our attorneys have worked on cases in which the very constitutionality of both state and municipality taxing authority were called into question.

Case Studies

Roads Paving Washington, LLC v. DOR, Board of Tax Appeals Docket No. 18-057, opinion dated May 11, 2021, DOR’s reconsideration denied July 7, 2021.  The firm successfully challenged the Department of Revenue’s assertion of fraud penalties in a case where the taxpayer’s CPA provided incorrect advice, which resulted in a significant underpayment of state sales tax.  The case is unique in that it was decided on summary judgment – a rarity as most fraud cases are highly fact specific. 

Determination No. 14-0157.  Successfully argued that out-of-state manufacturer of beverage additive was not subject to B&O tax because the goods were delivered and received outside of Washington.

Determination No. 12-0111.  Prevailed entirely before the ALJ in case involving sales tax liability for a popular bar and restaurant.

Determination No. 12-300.  Successfully challenged the Department of Revenue’s attempt to pierce the corporate veil and collect use tax on a $5 million yacht from the LLC’s member.

Determination No. 15-0031.  Represented an out-of-state manufacturer against the Department of Revenue’s assertion that its sales to Washington retailers were not associated with any Washington activities and were therefore exempt from B&O tax.  Negotiated a favorable settlement with the DOR.

Determination No. 12-0011.  Successfully defended assertion of use tax against government contractor who built prototypes for the Defense Department.

Represented a construction company in an audit involving the proper classification of workers; negotiations led to a settlement resulting in 90% concession by the Department of Labor & Industries.

Represented a general contractor in an audit involving employment of undocumented workers, and worker classification over a multi-year period.  The resolution limited the contractor’s exposure to a single year.

Obtained full concession that DOR’s assertion that services provided by client were not subject to retail sales tax.

Successfully shielded client from L&I’s attempt to assert personal liability against client for unpaid corporate L&I premiums.

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