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JAY WOLFE IMPORTS MISSOURI, INC. v. DIRECTOR OF REVENUE

No. SC 89568.

282 S.W.3d 839 (2009)

JAY WOLFE IMPORTS MISSOURI, INC., Appellant, v. DIRECTOR OF REVENUE, Respondent.

Supreme Court of Missouri, En Banc.

May 5, 2009.

Attorney(s) appearing for the Case

Bruce C. Davison, Sonnenschein Nath & Rosenthal LLP, Kansas City, MO, for Appellant.

Chris Koster, Atty. Gen., James R. Layton, Office of Mo. Atty. Gen., Jefferson City, MO, for Respondent.

MARY R. RUSSELL, Judge.

At issue in this case is whether a Missouri car dealership owes less income tax for sales made in Missouri to out-of-state customers. The Administrative Hearing Commission rejected the dealership's contention that it is entitled to apportion its income for taxation purposes under section 143.451.2(2)(b), RSMo 2000,1 as it found that the dealership's sales to out-of-state customers were taxable as sales wholly within...

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