Legal Opinion · Concurring in part, dissenting in part
All Star Amusement, Inc. v. Director of Revenue
Supreme Court of Missouri
Decided April 26, 1994No. 076539Published
1Concurring in part, dissenting in part
JOSEPH M. ELLIS, Special Judge,
concurring in part and dissenting in part.
I concur with the majority that the AHC erred, as a matter of law, in holding that an exemption certificate is void unless it is dated and received contemporaneously with the sale. However, I must respectfully dissent insofar as the opinion gives § 32.200, RSMo 1986, the Multistate Tax Compact as adopted in Missouri, the effect of substantive tax law.
In Goldberg v. State Tax Comm’n, 639 S.W.2d 796, 799 (Mo. banc 1982), this Court declared:
The Compact was never intended by anyone to be a substantive taxation statute. ...…
2Cases cited16 opinions
- Northwestern States Portland Cement Co. v. MinnesotaSupreme Court of the United States · 1959
- Carter v. South Central BellSupreme Court of the United States · 1991
- United States Steel Corp. v. Multistate Tax CommissionSupreme Court of the United States · 1978
- Brown Group, Inc. v. Administrative Hearing CommissionSupreme Court of Missouri · 1983
- Goldberg v. State Tax CommissionSupreme Court of Missouri · 1982
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