Dick Proctor Imports, Inc. v. Director of Revenue

BILLINGS, Chief Justice.

Dick Proctor Imports, Inc., challenges a decision of the Director of Revenue finding deficiencies in its payment of income taxes for the period between April 1, 1978 and December 31, 1979. The issues are whether appellant was entitled to apportion income pursuant to the single factor apportionment formula contained in § 143.451.-2(2)(b), RSMo 1986, and, if so, whether it properly applied this formula to its sales for the time period in question. The Court concludes that appellant was entitled to use the single factor apportionment formula but that the case must be…