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Durham School Services LP v. State Department of Revenue - Tax Appeal

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Summary

Durham School Services LP Department of Revenue tax appeal

What changed

The Washington Court of Appeals Division II issued a decision in the tax appeal filed by Durham School Services LP against the State Department of Revenue. The court affirmed the judgment from Thurston Superior Court, which had ruled in favor of the Department of Revenue regarding a tax assessment. The appellate panel, authored by Judge Linda Lee with concurrences from Judges Rebecca Glasgow and Meng Li Che, upheld the lower court's determination. This unpublished opinion (GR 14.1(a)) represents the final appellate ruling in this matter.

For businesses operating in Washington, particularly transportation companies and public companies with multi-state operations, this ruling reinforces the Department of Revenue's position on tax assessment methodology. Companies should review their state tax compliance procedures and consider consulting with tax counsel to ensure their filing positions align with Washington administrative interpretation. The precedent may influence how similar disputes are resolved in future Department of Revenue audits and appeals.

What to do next

  1. Review state tax compliance procedures for multi-state operations
  2. Consult tax counsel on implications for similar disputes
  3. Monitor for any petition for review to Washington Supreme Court

Archived snapshot

Apr 9, 2026

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DO NOT CITE. SEE GR 14.1(a).
Court of Appeals Division II
State of Washington

Opinion Information Sheet

| Docket Number: | 59934-1 |
| Title of Case: | Durham School Services Lp, Appellant V. State Department Of Revenue, Respondent |
| File Date: | 04/07/2026 |

SOURCE OF APPEAL

| Appeal from Thurston Superior Court | |
| Docket No: | 20-2-02529-9 |
| Judgment or order under review | |
| Date filed: | 07/23/2024 |
| Judge signing: | Honorable Allyson S Zipp |

JUDGES

| Authored by | Linda Lee |
| Concurring: | Rebecca Glasgow |
| | Meng Li Che |

COUNSEL OF RECORD

| Counsel for Appellant(s) | |
| | Brett S Durbin |
| | Ballard Spahr LLP |
| | 1301 2nd Ave Ste 2800 |
| | Seattle, WA, 98101-3808 |
| | |
| | Daniel A Kittle |
| | Ballard Spahr LLP |
| | 1301 2nd Ave Ste 2800 |
| | Seattle, WA, 98101-3808 |
| | |
| | Aaron Charles Johnson |
| | Ballard Spahr LLP |
| | 1301 2nd Ave Ste 2800 |
| | Seattle, WA, 98101-3808 |
| Counsel for Respondent(s) | |
| | Jessica E Fogel |
| | Washington Attorney General's Office |
| | Po Box 40123 |
| | Olympia, WA, 98504-0123 |
| | |
| | Kate Adams |
| | Washington State Office of the Attorney |
| | 7141 Cleanwater Dr Sw |
| | Tumwater, WA, 98501-6503 |
| | |
| | Dept of Revenue A.g. Office |
| | Attorney at Law |
| | 7141 Cleanwater Lane Sw |
| | P O Box 40123 |
| | Olympia, WA, 98504-0123 |

View the Slip Opinion(s) Filed for this Case.

View a Printer Friendly Version of this Opinion Information Sheet.

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Source document text, dates, docket IDs, and authority are extracted directly from WA Court of Appeals II.

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Last updated

Classification

Agency
WA Court of Appeals II
Filed
April 7th, 2026
Instrument
Enforcement
Legal weight
Binding
Stage
Final
Change scope
Substantive
Document ID
Docket No. 59934-1 (WA Ct. App. Div. II Apr. 7, 2026)
Docket
59934-1 20-2-02529-9

Who this affects

Applies to
Public companies Government agencies
Industry sector
4841 Trucking & Logistics
Activity scope
State tax appeals Transportation services
Geographic scope
Washington US-WA

Taxonomy

Primary area
Taxation
Operational domain
Legal
Topics
Judicial Administration

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