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The full case caption appears at the end of this opinion.

This dispute between Simpson Investment Company (Simpson) andthe State Department of Revenue (Department) presents the question ofwhether Simpson, a holding corporation for multiple subsidiaries, is a’financial business’ for purposes of RCW 82.04.4281 (section 4281).Section 4281 provides a Business and Occupational (B&O) tax deduction forthe investment income of all persons not ‘engaging in banking, loan,security, or other financial businesses.’ RCW 82.04.4281. The Departmentassessed B&O taxes against Simpson, claiming it was not entitled to deductits investment income because it is a ‘financial business.’ Simpsoncontested this assessment in a refund action, culminating in motions forsummary judgment. The Thurston County Superior Court denied Simpson’smotion, granting summary judgment to the Department, and Simpson appealed.The Court of Appeals reversed, determining that Simpson is not a ‘financialbusiness’ and is therefore entitled to deduct its investment income incalculating its B&O tax liability. Simpson Inv. Co. v. Department ofRevenue, 92 Wn. App. 905, 965 P.2d 654 (1998). We find that Simpson is afinancial business and reverse the Court of Appeals.

 
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