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AQUILA FOREIGN QUALIF. v. DIR. OF REVENUE

No. SC 91784.

362 S.W.3d 1 (2012)

AQUILA FOREIGN QUALIFICATIONS CORPORATION, Respondent, v. DIRECTOR OF REVENUE, Appellant.

Supreme Court of Missouri, En Banc.

March 6, 2012.

Attorney(s) appearing for the Case

Jeremiah J. Morgan , Deputy Solicitor General, Attorney General's Office, Jefferson City, for the Director.

Bruce Farmer , Oliver Walker Wilson LLC, Columbia, for Aquila.

MARY R. RUSSELL, Judge.

The issue before this Court is whether a convenience store is exempt from sales and use tax for the electricity it purchases for its food preparation operations. Although section 144.054.21 provides a tax exemption for the "processing" of products, this Court holds that the legislature did not intend the term "processing" to include retail food preparation in section 144.054.2. The decision of the administrative...

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