Revised Code of Washington

Wash. Rev. Code § 82.32A.020 (2026)

Rights

✓ current as of May 2026

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The taxpayers of the state of Washington have:

(1) The right to a written explanation of the basis for any tax deficiency assessment, interest, and penalties at the time the assessments are issued;

(2) The right to rely on specific, official written advice and written tax reporting instructions from the department of revenue to that taxpayer, and to have interest, penalties, and in some instances, tax deficiency assessments waived where the taxpayer has so relied to their proven detriment;

(3) The right to redress and relief where tax laws or rules are found to be unconstitutional by the final decision of a court of record and the right to prompt administrative remedies in such cases;

(4) The right to confidentiality and protection from public inquiry regarding financial and business information in the possession of the department of revenue in accordance with the requirements of RCW 82.32.330;

(5) The right to receive, upon request, clear and current tax instructions, rules, procedures, forms, and other tax information; and

(6) The right to a prompt and independent administrative review by the department of revenue of a decision to revoke a tax registration, and to a written determination that either sustains the revocation or reinstates the registration.

[ 1991 c 142 s 4.]

Notes of Decisions

Cited in 8 cases (4 in the last 5 years), 2005–2025 · leading case: TracFone Wireless, Inc. v. Dep't of Revenue, 242 P.3d 810 (Wash. 2010).

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TracFone Wireless, Inc. v. Dep't of Revenue, 242 P.3d 810 (Wash. 2010). · cites it 3× “¶36 TracFone contends, however, that the Department has failed to explain how it can collect the tax and thus is in violation of RCW 82.32A.020(5), which states that the taxpayer has “[t]he right to receive, upon request, clear and current tax instructions, rules, procedures,…”

Ass'n of Washington Bus. v. Dep't of Revenue, 120 P.3d 46 (Wash. 2005). “” RCW 82.32A.020(5). Further still, DOR has the responsibility to publish “written bulletins, instructions, current revenue laws, rules, court decisions, and interpretive rulings of the department of revenue,” making all of these items available to the public.”

Envolve Pharmacy Solutions, Inc., V. State Of Wa, Dept Of Revenue, 524 P.3d 1066 (Wash. Ct. App. 2023). · cites it 2× “The court also held that Envolve was entitled to rely on the Department’s letter ruling under RCW 82.32A.020. The trial court’s order required the Department to refund the B&O tax Envolve paid on its PBM services income.”

Express Scripts, Inc., V State Of Wa Dept. Of Revenue (Wash. Ct. App. 2019). · cites it 2× “The Department responds that ESI is not entitled to relief under the Act because ESI provided no evidence supporting its contention that it reasonably relied on the prior audit.”

Tracfone Wireless v. Dept. of Revenue, 242 P.3d 810 (Wash. 2010). · cites it 3× “¶ 36 TracFone contends, however, that the Department has failed to explain how it can collect the tax and thus is in violation of RCW 82.32A.020(5), which states that the taxpayer has "[t]he right to receive, upon request, clear and current tax instructions, rules, procedures,…”

Envolve Pharmacy Sols., Inc. v. Dep't of Revenue (Wash. 2024). “7 (quoting RCW 82.32A.020(2)). 22 Envolve Pharmacy Sols.”

Fujifilm Sonosite Inc., V. Washington State Dep't Of Revenue (Wash. Ct. App. 2025). “” RCW 82.32A.020(2). At the time SonoSite requested the letter ruling, DOR required taxpayers to submit a ruling request “in writing, contain[ing] all pertinent facts concerning the question presented.”

— Wash. Rev. Code § 82.32A.020(2) — 5 cases

Envolve Pharmacy Solutions, Inc., V. State Of Wa, Dept Of Revenue, 524 P.3d 1066 (Wash. Ct. App. 2023). “The court also held that Envolve was entitled to rely on the Department’s letter ruling under RCW 82.32A.020. The trial court’s order required the Department to refund the B&O tax Envolve paid on its PBM services income.”

Express Scripts, Inc., V State Of Wa Dept. Of Revenue (Wash. Ct. App. 2019). “The Department responds that ESI is not entitled to relief under the Act because ESI provided no evidence supporting its contention that it reasonably relied on the prior audit.”

Envolve Pharmacy Sols., Inc. v. Dep't of Revenue (Wash. 2024). “7 (quoting RCW 82.32A.020(2)). 22 Envolve Pharmacy Sols.”

— Wash. Rev. Code § 82.32A.020(5) — 3 cases

TracFone Wireless, Inc. v. Dep't of Revenue, 242 P.3d 810 (Wash. 2010). “¶36 TracFone contends, however, that the Department has failed to explain how it can collect the tax and thus is in violation of RCW 82.32A.020(5), which states that the taxpayer has “[t]he right to receive, upon request, clear and current tax instructions, rules, procedures,…”

Tracfone Wireless v. Dept. of Revenue, 242 P.3d 810 (Wash. 2010). “¶ 36 TracFone contends, however, that the Department has failed to explain how it can collect the tax and thus is in violation of RCW 82.32A.020(5), which states that the taxpayer has "[t]he right to receive, upon request, clear and current tax instructions, rules, procedures,…”

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