Homestake Lead Co. v. Director of Revenue

BLACKMAR, Judge.

The taxpayers, Homestake Lead Company of Missouri and Homestake Smelting Company, are wholly owned subsidiaries of Homestake Mining Company. All are California corporations. Taxpayers are engaged principally in the mining and processing of lead in Missouri. For the tax years in issue, 1976, 1977, 1978 and 1979 for “Lead,” and 1977 and 1979 for “Smelting,” each filed a separate Missouri corporation income tax return, making use of the single factor allocation formula authorized by § 143.451.2(2), RSMo 1986.

The director of revenue, in January and February of 1981, issued notices…