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GUTKNECHT v. DIRECTOR OF REVENUE

No. 63905.

867 S.W.2d 709 (1993)

Joe GUTKNECHT, d/b/a Joe Gutknecht & Associates, Petitioner/Appellant, v. DIRECTOR OF REVENUE, State of Missouri, Respondent/Respondent.

Missouri Court of Appeals, Eastern District, Division One.

December 28, 1993.

Attorney(s) appearing for the Case

H. Clay Billinsley, Klutho, Cody, Kilo & Flynn, St. Louis, for petitioner, appellant.

Jeremiah W. (Jay) Nixon, Atty. Gen., Gretchen Garrison, Asst. Atty. Gen., Jefferson City, for respondent, respondent.

REINHARD, Judge.

This is an appeal from the decision of the Administrative Hearing Commission (AHC). Petitioner is an architectural illustrator, doing business as Joe Gutknecht and Associates. The Director of Revenue (Director) assessed sales tax on petitioner's transfers of illustrations that petitioner had produced and delivered to his clients. Petitioner challenged the assessments, arguing that the "true object" of the transactions was the sale of his professional...

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