Wash. Rev. Code » Title 82 · Chapter 82.32
Revised Code of Washington

Wash. Rev. Code § 82.32.150 (2026)

✓ current as of May 2026
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All taxes, penalties, and interest shall be paid in full before any action may be instituted in any court to contest all or any part of such taxes, penalties, or interest. No restraining order or injunction shall be granted or issued by any court or judge to restrain or enjoin the collection of any tax or penalty or any part thereof, except upon the ground that the assessment thereof was in violation of the Constitution of the United States or that of the state.
[ 1961 c 15 s 82.32.150. Prior: 1935 c 180 s 198; RRS s 8370-198.]
Notes of Decisions
Cited in 20 cases (4 in the last 5 years), 1963–2024 · leading case: Tyler Pipe Indus., Inc. v. Dep't of Revenue, 638 P.2d 1213 (Wash. 1982).
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Tyler Pipe Indus., Inc. v. Dep't of Revenue, 638 P.2d 1213 (Wash. 1982). · cites it 15× “2 Plaintiff is entitled to an injunction under RCW 82.32.150 and a substantial constitutional question not definitely resolved by prior authorities is clearly presented in this case.”
AOL, LLC v. Dep't of Revenue, 149 Wash. App. 533 (Wash. Ct. App. 2009). · cites it 28× “*537 ¶1 AOL, LLC, appeals the Thurston County Superior Court’s dismissal of its excise tax refund lawsuit against the Washington Department of Revenue (Department), based on the trial court’s ruling that AOL had failed to pay “[a] 11 taxes, penalties, and interest [before…”
Aol, LLC v. Washington State Dept., 205 P.3d 159 (Wash. Ct. App. 2009). · cites it 34× “¶ 1 AOL, LLC appeals the Thurston County Superior Court's dismissal of its excise tax refund lawsuit against the Washington Department of Revenue (Department), based on the trial court's ruling that AOL had failed to pay "all taxes, penalties, and interest [before *161…”
Booker Auction Co. v. Dept. of Revenue, 241 P.3d 439 (Wash. Ct. App. 2010). · cites it 6× “) ¶ 10 Additionally, RCW 82.32.150 states: All taxes, penalties, and interest shall be paid in full before any action may be instituted in any court to contest all or any part of such taxes, penalties, or interest.”
Booker Auction Co. v. Dep't of Revenue, 158 Wash. App. 84 (Wash. Ct. App. 2010). · cites it 6× “) ¶10 Additionally, RCW 82.32.150 states: All taxes, penalties, and interest shall be paid in full before any action may be instituted in any court to contest all or any part of such taxes, penalties, or interest.”
W.R. Grace & Co. v. Dep't of Revenue, 973 P.2d 1011 (Wash. 1999). · cites it 2× “Application of the 1987 MATC Does Not Offend Due Process The taxpayers also assert because the B&O tax was found unconstitutional in Tyler Pipe, anything less than either the enjoining of the collection of taxes pursuant to RCW 82.”
Kirkland v. Dep't of Revenue, 727 P.2d 254 (Wash. Ct. App. 1986). · cites it 4× “RCW 82.32.150. That statute provides: "All taxes, penalties, and interest shall be paid in full before any action may be instituted in any court to contest all or any part of such taxes, penalties, or interest.”
Lamtec Corp. v. Dep't of Revenue of State, 215 P.3d 968 (Wash. Ct. App. 2009). “See RCW 82.32.150. [3] RCW 82.04.220 reads in pertinent part: There is levied and shall be collected from every person a tax for the act or privilege of engaging in business activities.”
Lamtec Corp. v. Dep't of Revenue, 151 Wash. App. 451 (Wash. Ct. App. 2009). “See RCW 82.32.150. RCW 82.04.220 reads in pertinent part: There is levied and shall be collected from every person a tax for the act or privilege of engaging in business activities.”
Shutt v. Moore, 613 P.2d 1188 (Wash. Ct. App. 1980). “180 provides for a judicial determination of tax liability once payment of the tax is made; and RCW 82.32.150 provides that prepayment is waived if the statute's constitutionality is challenged.”
Phillip Edward Sifferman, V. Chelan Cnty. (Wash. Ct. App. 2021). · cites it 33× “24 RCW and RCW 82.32.150, (2) the amount of tax they paid was incorrect under state law, (3) federal law preempts imposition of the REET on transfers of subleases on Native American land, (4) imposition of the REET violated their rights to due process arising under the…”
Puget Sound Energy v. Dep't of Revenue, 158 Wash. App. 616 (Wash. Ct. App. 2010). “5 ¶5 In late 2007, PSE filed an action in Thurston County Superior Court under RCW 82.32.150 and RCW 82.32.180, seeking a refund of taxes paid.”
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