ROBERTSON, Judge.
Hayes Drilling, Inc., (Hayes) elected to compute its state income tax in accordance with § 143.451.2, RSMo 1978, for its tax years ending February 28, 1981 and 1982. The Director of Revenue, following audit, assessed an additional tax of $880 for 1981 and $589 for 1982, on the basis that Hayes should have included 50 percent of the corporation's income from transactions allegedly occurring partly in Missouri and partly in other states. Hayes...
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