Hudson Foods, Inc. v. Director of Revenue

LIMBAUGH, Judge.

Hudson Foods, Inc. (Hudson) appeals the decision of the Administrative Hearing Commission (AHC) upholding the Director of Revenue’s denial of Hudson’s application for a direct pay authorization and sales tax exemption under § 144.030.2(12), RSMo 1994. Specifically, Hudson takes issue with the AHC’s determination that the chilling, partial freezing, and solid freezing of dressed turkeys and chickens does not constitute secondary processing as that term is used in the statute. Because this case involves the construction of § 144.030.2(12), a revenue statute, we have…