Wash. Rev. Code » Title 82 · Chapter 82.03
Revised Code of Washington

Wash. Rev. Code § 82.03.180 (2025)

Judicial review

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Judicial review of a decision of the board of tax appeals shall be de novo in accordance with the provisions of RCW 82.32.180 or 84.68.020 as applicable except when the decision has been rendered pursuant to a formal hearing elected under RCW 82.03.140 or 82.03.190, in which event judicial review may be obtained only pursuant to RCW 34.05.510 through 34.05.598: PROVIDED, HOWEVER, That nothing herein shall be construed to modify the rights of a taxpayer conferred by RCW 82.32.180 and 84.68.020 to sue for tax refunds: AND PROVIDED FURTHER, That no review from a decision made pursuant to RCW 82.03.130(1)(a) may be obtained by a taxpayer unless within the petition period provided by RCW 34.05.542 the taxpayer shall have first paid in full the contested tax, together with all penalties and interest thereon, if any. The director of revenue shall have the same right of review from a decision made pursuant to RCW 82.03.130(1)(a) as does a taxpayer; and the director of revenue and all parties to an appeal under RCW 82.03.130(1)(e) shall have the right of review from a decision made pursuant to RCW 82.03.130(1)(e).
[ 2000 c 103 s 4; 1989 c 175 s 176; 1982 1st ex.s. c 46 s 9; 1967 ex.s. c 26 s 47.]

Notes:

Effective date—1989 c 175: See note following RCW 34.05.010.
Notes of Decisions
Cited in 40 cases (7 in the last 5 years), 1974–2026 · leading case: Del Pettit v. Bd. of Tax Appeals, 538 P.2d 501 (Wash. 1975).
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Del Pettit v. Bd. of Tax Appeals, 538 P.2d 501 (Wash. 1975). · cites it 9× “We must decide whether the assessor can obtain judicial review of a decision of the Board of Tax Appeals by way of either RCW 82.03.180 or the inherent review power of the superior court.”
Burlington N., Inc. v. Johnston, 572 P.2d 1085 (Wash. 1977). · cites it 2× “RCW 82.03.180, providing for judicial review of decisions of the Board of Tax Appeals, allows the Director of Revenue to appeal only from decisions made pursuant to RCW 82.”
Booker Auction Co. v. Dept. of Revenue, 241 P.3d 439 (Wash. Ct. App. 2010). · cites it 3× “130(1)(a) may be obtained by a taxpayer unless within the petition period provided by RCW 34.05.542 the taxpayer shall have first paid in full the contested tax.”
Booker Auction Co. v. Dep't of Revenue, 158 Wash. App. 84 (Wash. Ct. App. 2010). · cites it 3× “130(l)(a) may be obtained by a taxpayer unless within the petition period provided by RCW 34.05.542 the taxpayer shall have first paid in full the contested tax.”
Sprint Spectrum, LP v. Dep't of Revenue, 156 Wash. App. 949 (Wash. Ct. App. 2010). · cites it 2× “This noncompliance with the service requirements of the statute supports the superior court’s dismissal of the petition.”
Sprint Spectrum v. State, Dept. of Revenue, 235 P.3d 849 (Wash. Ct. App. 2010). · cites it 2× “What consequences will then flow from a failure to comply with the statutory service requirements is a question that will have to await further briefing and analysis.”
United Parcel Serv., Inc. v. Dep't of Revenue, 687 P.2d 186 (Wash. 1984). “UPS petitioned for review in Superior Court pursuant to RCW 34.04.”
Banner Realty, Inc. v. Dep't of Revenue, 738 P.2d 279 (Wash. Ct. App. 1987). · cites it 2× “RCW 82.03.180, in turn, governs judicial review of decisions of the BTA.”
Boise Cascade Corp. v. Pierce Cnty., 529 P.2d 9 (Wash. 1974). · cites it 4× “This case involves an action brought by the plaintiff (appellant), Boise Cascade Corporation (hereinafter referred to as "Boise"), against the defendant (respondent), Pierce County, in the Superior Court for Pierce County, to review a decision by the Washington State Board of…”
Steven Klein, Inc. v. Dep't of Revenue, 357 P.3d 59 (Wash. 2015). “RCW 82.03.180. Under the APA, we may grant relief from an agency order when “[t]he agency has erroneously interpreted or applied the law.”
Transamerica Title Ins. v. Hoppe, 611 P.2d 1361 (Wash. Ct. App. 1980). · cites it 6× “Does RCW 82.03.180 preserve the right to judicial review of a Board of Tax Appeals decision made after an informal hearing? 2.”
Washington State Liquor Control Bd. v. Washington State Pers. Bd., 561 P.2d 195 (Wash. 1977). “RCW 82.03.180 provides in part: "The director of revenue *374 shall have the same right of review from a decision .”
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