Wash. Rev. Code » Title 82 · Chapter 82.45
Revised Code of Washington

Wash. Rev. Code § 82.45.080 (2026)

Tax is seller's obligation—Choice of remedies

✓ current as of May 2026
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(1) The tax levied under this chapter is the obligation of the seller and the department may, at the department's option, enforce the obligation through an action of debt against the seller or the department may proceed in the manner prescribed for the foreclosure of mortgages. The department's use of one course of enforcement is not an election not to pursue the other.
(2) For purposes of this section and notwithstanding any other provisions of law, the seller is the parent corporation of a wholly owned subsidiary, when such subsidiary is the transferor to a third-party transferee and the subsidiary is dissolved before paying the tax imposed under this chapter.
[ 2010 1st sp.s. c 23 s 210; 1980 c 154 s 3; 1969 ex.s. c 223 s 28A.45.080. Prior: 1951 1st ex.s. c 11 s 10. Formerly RCW 28A.45.080, 28.45.080.]

Notes:

Effective date—2010 1st sp.s. c 23: See note following RCW 82.32.655.
Findings—Intent—2010 1st sp.s. c 23: See notes following RCW 82.04.220.
Purpose—Effective dates—Savings—Disposition of certain funds—Severability—1980 c 154: See notes following chapter digest.
Notes of Decisions
Cited in 3 cases (1 in the last 5 years), 1991–2021 · leading case: Phillip Edward Sifferman, V. Chelan Cnty. (Wash. Ct. App. 2021).
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Phillip Edward Sifferman, V. Chelan Cnty. (Wash. Ct. App. 2021). “060(1); RCW 82.45.080(1). A “sale” of real property is defined as, any conveyance, grant, assignment, quitclaim, or transfer of the ownership of or title to real property, including standing timber, or any estate or interest therein for a valuable consideration, and any contract…”
Ranjiv Hayre v. Dean Street (Wash. Ct. App. 2013). “And, RCW 82.45.080 provides that the excise tax is the seller's obligation.”
Groesbeck v. Dep't of Revenue, 818 P.2d 1121 (Wash. Ct. App. 1991). “For the same reason, equally unpersuasive is the Department's second assertion, that somehow this was not an assumption because Sodorff thereafter chose to refinance the property with another lender rather than to continue payments to Groesbeck's mortgagee. This was a distress…”
— Wash. Rev. Code § 82.45.080(1) — 1 case
Phillip Edward Sifferman, V. Chelan Cnty. (Wash. Ct. App. 2021). “060(1); RCW 82.45.080(1). A “sale” of real property is defined as, any conveyance, grant, assignment, quitclaim, or transfer of the ownership of or title to real property, including standing timber, or any estate or interest therein for a valuable consideration, and any contract…”
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