Court of Appeals of Washington January 30, 2006, No. 55049-7-I (Sprint Spectrum, L.P. v. City of Seattle)

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Schindler, J.

— Sprint Spectrum, L.P./Sprint PCS (Sprint) sells cellular service and equipment to customers throughout the United States. As a cellular business, Sprint is subject to the city of Seattle’s telephone business utility tax. Seattle Municipal Code (SMC) ch. 5.48. The telephone utility tax is based on the total gross income from Sprint’s cellular business activity in Seattle.