Westfall v. Director of Revenue

LOWENSTEIN, Judge.

Appellant Westfall, trustee of a trust under the will of Curtis B. Rollins, Jr., (“Rollins Trust”) appeals from a judgment affirming the decision of the Director of Revenue to deny Westfall’s claim for a tax refund.

The issue posed concerns whether Missouri may tax all of a trust’s income even though only a portion of the income derives from assets held in Missouri. Westfall filed this appeal in the Supreme Court of Missouri, contending this case concerns the construction and validity of Missouri revenue laws. The Supreme Court transferred it to this court.

Both parties…