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  5. 960 S.W.2d 503 (1998)
 

MAXLAND DEVELOPMENT v. DIRECTOR OF REV.

Nos. 80037, 80040 and 80041.

960 S.W.2d 503 (1998)

MAXLAND DEVELOPMENT CORPORATION, et al., Appellants, v. DIRECTOR OF REVENUE, Respondent. MAXLUNE REALTY CORPORATION & Tobeck Realty Corporation, Appellants, v. DIRECTOR OF REVENUE, Respondent. PAJIA REALTY CORPORATION & Jopat Building Corporation, Appellants, v. DIRECTOR OF REVENUE, Respondent.

Supreme Court of Missouri, En Banc.

January 27, 1998.

Attorney(s) appearing for the Case

Terrence F. Moffitt, Law Office of Thomas R. Green, St. Louis, for Appellants.

Jeremiah W. (Jay) Nixon, Atty. Gen., Edward F. Downey, Asst. Atty. Gen., Jefferson City, for Respondent.

BENTON, Chief Justice.

The appellant Missouri corporations computed their state income tax by electing the single-factor method. Section 143.451.2(2)(b).1 The appellants classified rental income from out-of-state properties as "wholly without Missouri." The Director of Revenue and the Administrative Hearing Commission reclassified this income as "partly within and partly without Missouri." This appeal followed. Mo. Const. art...

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