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EILIAN v. DIRECTOR OF REVENUE

No. SC 93075.

402 S.W.3d 566 (2013)

Jonathan D. EILIAN and Amanda A. Eilian, Respondents, v. DIRECTOR OF REVENUE, Appellant.

Supreme Court of Missouri, En Banc.

June 11, 2013.

Attorney(s) appearing for the Case

Trevor S. Bossert and Deputy Solicitor General, Jeremiah J. Morgan , Attorney General's Office, Jefferson City, for Director.

J. Kent Lowry and Scott Hunt , Armstrong Teasdale LLP, Jefferson City, for Eilians.

PAUL C. WILSON, Judge.

From time to time, the tiny two-lane gravel road of common sense intersects the superhighway of tax law. It is a dangerous crossing, to be sure, and one to be navigated with great care. Here, the common sense route was mapped out more than a generation ago in Brown Group, Inc. v. Administrative Hearing Commission, 649 S.W.2d 874 (Mo. banc 1983). Because Mr. and Mrs. Eilian have failed to persuade the...

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