Minact, Inc. v. Director of Revenue

RICHARD B. TEITELMAN, District Judge.

The director of revenue appeals a decision of the Administrative Hearing Commission holding that income from a “rabbi trust” used to fund a deferred compensation plan for company executives does not constitute “business income” subject to apportionment and taxation in Missouri pursuant to section 32.200, RSMo Supp.2013. 1 “Business income” under section 32.200 “includes income from tangible and intangible property if the acquisition, management, and disposition of the property constitute integral parts of the taxpayer’s regular trade or business…