Brown Group, Inc. v. Administrative Hearing Commission

GUNN, Judge.

This appeal involves construction of the revenue laws; therefore, jurisdiction is vested in this Court pursuant to Mo. Const, art. V, § 3. Petitioner raises four issues on appeal: (1) Whether federal taxable income under § 143.431, RSMo 19781 may be less than zero; (2) whether additional assessments may be made by subordinates of the Director of Revenue; (3) whether royalties paid by a foreign corporation to petitioner may be excluded from the multiplicand of the single factor formula; and (4) whether the applicable statute of limitations is four years under § 143.240, RSMo 1969…