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  5. 641 S.W.2d 69 (1982)
 

STATE TAX COM'N v. ADMINISTRATIVE HEARING COM'N

No. 63065.

641 S.W.2d 69 (1982)

STATE TAX COMMISSION of Missouri, Samuel C. Jones, et al., Petitioners, v. ADMINISTRATIVE HEARING COMMISSION, et al., Respondents.

Supreme Court of Missouri, En Banc.

November 9, 1982.

Attorney(s) appearing for the Case

John Ashcroft, Atty. Gen., Richard L. Wieler, Asst. Atty. Gen., Jefferson City, Philip R. Baker, State Tax Com'n of Mo., Jefferson City, for petitioners.

James D. Eckhoff, Fordyce & Mayne, P.C., St. Louis, for respondents.

WELLIVER, Judge.

The State Tax Commission circulated a letter to assessors and certain taxpayers stating that it had adopted a described formula for determining the valuation of leased tangible personal property. The State Tax Commission now petitions pursuant to § 161.337, RSMo 1978,1 for review of the Administrative Hearing Commission's declaratory judgment holding that the letter constituted an agency rule that was invalid because...

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