Sports Unlimited, Inc. v. Director of Revenue

LIMBAUGH, Judge.

Sports Unlimited, Inc., appeals the decision of the Administrative Hearing Commission (“AHC”) upholding the Director of Revenue’s (Director) assessment of use taxes on materials used in fifteen of Sports Unlimited’s construction projects in Missouri. Because resolution of the appeal requires the construction of a revenue law — section 144.062, RSMo Supp.1988 — this Court has exclusive jurisdiction. Mo. Const. art. V, sec. 3; section 621.189, RSMo 1994. The decision of the AHC is reversed.

The facts are uncontested. Sports Unlimited is an Oklahoma corporation engaged in the sale…