Kohn v. Mo. Dep't of Revenue

Mr. Michael E. Kohn and Ms. Catherine E. Kohn, husband and wife (collectively, "the Kohns"), appeal from the judgment of the Circuit Court of Cole County, Missouri ("trial court"), dismissing their petition for declaratory judgment against Mr. Joel W. Walters, Director of the Missouri Department of Revenue ("DOR"), for failure to state a claim upon which relief can be granted. We affirm.

Facts and Procedural History1

On February 13, 2005, the DOR assessed individual income taxes against the Kohns for tax year 2001 in the amount of $69,134.00, with additions to tax of $17,283.50, accrued…