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Attorney: Former Supreme Court Justice Talmadge is Wrong on 1098

The PI.com—which has been obsessing over Initiative 1098, the high-earners’ income tax—has an interview today with prominent Seattle attorney Hugh Spitzer, who strongly disagrees with former state supreme court justice Phil Talmadge’s assessment that the initiative is unconstitutional. (Talmadge argued yesterday that the tax was unconstitutional because, in his opinion, income constitutes property, and the state constitution places limits on property tax rates.)

However, Spitzer argues today that income isn’t property, calling that an “antiquated view” that only two states, including Washington, still have on the books.

“It’s a very isolated view of what income is,” Spitzer told the PI. “Most courts view income as an asset only once you have received it and are holding it. But they don’t view income flowing into you as property for state tax purposes.” Spitzer notes that the case Talmadge referred to in his opinion was from 1933.

“Fundamentally, the cases they relied on in 1933 all tied back to three United States Supreme Court cases which have been reversed or, in one case, wiped out by a U.S. Constitutional amendment. The background law no longer exists.”

Read the PI’s whole interview with Spitzer here.




  • gloomy gus

    Spitzer runs rings around Talmadge. Good for him.

  • F.O.T.

    Talmadge isn’t saying “in his opinion, income constitutes property,” he’s saying his opinion is that that is what the State Supreme Court will rule.
    Also, Talmadge specifically cited a 1999 case. Here’s the quote: “Talmadge points to a 1999 decision in which justices threw out a fee on residential units imposed by the City of Mukilteo. Talmadge says Harbour Village Apartments v. City of Mukilteo would likely be used against I-1098.”
    So writing “Spitzer notes that the case Talmadge referred to in his opinion was from 1933″ is frankly highly misleading and unfair. It implies Talmadge’s opinion is based only the 1933 cases, but it’s not. Rather than jsut report legal issues as X v. Y personal contests, maybe tell us what the 1999 case said?

    (BTW Talmdadge may be on record as saying he personally favors an ncome tax. He certainly favored one of the biggest tax increases in our state’s history when he led the 1992 health care reform legislation in the senate, that then got wiped out by the republican tide after 1994).

  • rtm

    They are both really smart guys. I tend to put a lot of stock in what Hugh says.