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PRODUCTION CREDIT ASS'N v. DIRECTOR OF REV.

Nos. SC 81407, SC 81727.

10 S.W.3d 142 (2000)

PRODUCTION CREDIT ASSOCIATION OF SOUTHEASTERN MISSOURI, et al., Appellants, v. DIRECTOR OF REVENUE, Respondent. CoBank, ACB, as Successor to The National Bank for Cooperatives, Appellant, v. Director of Revenue, State of Missouri, Respondent.

Supreme Court of Missouri, En Banc.

January 25, 2000.

Attorney(s) appearing for the Case

Mark W. Nichols, Nichols & Campbell, P.A., Little Rock, Ark., Stephen P. Carlton, Carthage, Mo., for appellants in cause no. SC81407.

Richard A. Hanson, Theodore H. Bots, McDermott, Will & Emery, Chicago, Ill., Juan D. Keller, John P. Barrie, B. Derek Rose, St. Louis, for Appellant in cause no. SC81727.

Jeremiah W. (Jay) Nixon, Atty. Gen., James R. Layton, Evan J. Buchheim, Asst. Attys. Gen., Jefferson City, for Respondent in cause no SC81407.

Jeremiah W. (Jay) Nixon, Atty. Gen., James R. Layton, Wood Miller, Asst. Attys. Gen., Jefferson City, for Respondent in cause no. SC 81727.

STEPHEN N. LIMBAUGH, Jr., Judge.

This is a consolidated case in which several member institutions of the Farm Credit System seek review of the decisions of the Administrative Hearing Commission (AHC) upholding the Director of Revenue's (Director) assessment of corporate income tax. Appellants claim that their status as federal instrumentalities exempts them from corporate income tax unless Congress expressly consents to the tax, and that Congress has not given that...

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