Herschend v. Director of Revenue

LIMBAUGH, Judge.

Raymond and Kelly Herschend (the Herschends) seek a ruling that Tenn.Code Ann. § 67-4-806 (1994)1, a Tennessee corporate tax statute, is an “income tax” within the meaning of § 143.081.1, RSMo 1986, entitling them to a credit against their Missouri income tax liability. The Director of Revenue (Director), and, in turn, the Administrative Hearing Commission (AHC) determined that the Tennessee tax was not an “income tax,” and, therefore, denied the credit. Because resolution of the appeal requires construction of § 143.081.1, a revenue law, this Court has exclusive jurisdiction.…