Travelhost of Ozark Mountain Country v. Director of Revenue

ROBERTSON, Judge.

The Director of Revenue (the Director) assessed use tax against appellants, Travel-host of Ozark Mountain Country (Travel-host Ozark) and Mid-America Travelhost Enterprises, Inc. (Mid-America). Travel-host Ozark and Mid-America challenged the assessments, claiming an exemption from use taxation under Section 144.034, RSMo 1986. The issue is whether appellants’ purchase and distribution of Travel-host magazine on behalf of its advertising customers constitutes the tax-exempt sale of advertising.

The Administrative Hearing Commission (the Commission) found appellants’ business…