Rainier Bancorporation v. Department of Revenue

In Rainier Bancorporation v. Department of Revenue, 96 Wn.2d 669, 638 P.2d 575 (1982), the Court addressed RCW 82.04.4281 (section 4281). Rainier Bancorporation (Rainier) was a bank holding company registered with the Federal Reserve System. Rainier, 96 Wn.2d at 671. Rainier owned three subsidiaries, all engaged in banking related industries--Rainier Bank, Rainier Mortgage Company, and Rainier Credit Company--and was claiming entitlement to a section 4281 deduction. Id. Reaffirming Sellen's "common and ordinary" definition of financial business, this court held that Rainier was a "financial business" and therefore not entitled to deduct its investment income. Id. at 674. Central to the decision in Rainier was the fact that Rainier loaned money to its subsidiaries and charged interest for these loans. Rainier, 96 Wn.2d at 673 n.2. Less than one-half of the loaned funds came from Rainier's own accounts. Id. Instead, the majority of funds came originally from outside sources. Id. Interest income, from loans to subsidiaries, made up 41.1 percent of Rainier's gross income for one audit period and 58.1 percent for another. Id. at 673 n.2. While this fact was obviously relevant, the court specifically rejected the use of any percentage test in determining if a business is a financial business. Id. Rainier, using the doctrine of ejusdem generis, then held that these loans, among other things, made Rainier "comparable to" a banking, loan, or security business. Rainier, 96 Wn.2d at 674.