J.C. Nichols Co. v. Director of Revenue

ROBERTSON, Judge.

Two principal issues require resolution in this case: First, whether a taxpayer who segregates income by state but who utilizes a formula to allocate a portion of its expenses has segregated “income and deductions” and may avoid utilizing the single factor formula for determining Missouri income taxation, Section 143.451.2(1), RSMo 1986; and second, whether a taxpayer may assume approval by the Director of Revenue of its petitioned-for alternative accounting method by the silence of the Director and by filing income tax returns using that accounting method. Section 143.461.2,…