Citizens Electric Corp. v. Director of Department of Revenue

COVINGTON, Justice.

Citizens Electric Corporation seeks review of a decision of the Administrative Hearing Commission upholding a Missouri corporate franchise tax assessment by the Director of Revenue. The decision of the Commission is affirmed.

The facts are not in dispute. In 1941, Genevieve Electric was organized as a rural electric cooperative with a purpose similar to other rural electric cooperatives. In 1945, Genevieve Electric purchased an investor owned utility which, among other things, provided electrical service to the cities of Ste. Genevieve and Perryville, Missouri. Because…