LLOYD v. DIRECTOR OF REVENUE

No. 75179.

851 S.W.2d 519 (1993)

Harry J. LLOYD and Patricia A. Lloyd, Appellants, v. DIRECTOR OF REVENUE, Respondent.

Supreme Court of Missouri, En Banc.

Rehearing Denied May 25, 1993.


Attorney(s) appearing for the Case

Lawrence M. Berkowitz, Jason A. Reschly, Don M. Downing, Sandra J. Wunderlich, Kansas City, for appellants.

William L. Webster, Atty. Gen., Carole Lewis Iles, Asst. Atty. Gen., Curtis Thompson, Sp. Asst. Atty. Gen., Jefferson City, for respondent.


HOLSTEIN, Judge.

In 1987, 1988 and 1989 Harry J. Lloyd and Patricia A. Lloyd filed Missouri individual income tax returns in which they apportioned income taxable to them as a result of the activity of five S corporations.1 Following a 1990 audit of those tax returns, the apportionment was disallowed and a notice of deficiency was issued. The Lloyds protested the director of revenue's decision, but to no avail. The Lloyds then deposited...

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