J.C. NICHOLS CO. v. DIRECTOR OF REVENUE

No. 72014.

796 S.W.2d 16 (1990)

J.C. NICHOLS COMPANY, Appellant, v. DIRECTOR OF REVENUE, Respondent.

Supreme Court of Missouri, En Banc.

September 11, 1990.


Attorney(s) appearing for the Case

Charles P. Schleicher, Mark A. Firestone, Kansas City, for appellant.

William L. Webster, Atty. Gen., Mark Siedlik, Richard L. Wieler, Asst. Attys. Gen., George Cox, Raymond T. Wagner, Jr., Sp. Asst. Attys. Gen., Jefferson City, for respondent.


ROBERTSON, Judge.

Two principal issues require resolution in this case: First, whether a taxpayer who segregates income by state but who utilizes a formula to allocate a portion of its expenses has segregated "income and deductions" and may avoid utilizing the single factor formula for determining Missouri income taxation, Section 143.451.2(1), RSMo 1986; and second, whether a taxpayer may assume approval by the Director of Revenue of its petitioned-for alternative...

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