Production Credit Ass'n of Southeastern Missouri v. Director of Revenue

STEPHEN N. LIMBAUGH, Jr., Judge.

This is a consolidated case in which several member institutions of the Farm Credit System seek review of the decisions of the Administrative Hearing Commission (AHC) upholding the Director of Revenue’s (Director) assessment of corporate income tax. Appellants claim that their status as federal instrumentalities exempts them from corporate income tax unless Congress expressly consents to the tax, and that Congress has not given that consent. . Because appellants challenge the constitutional Validity of section 143.071, RSMo 1994, the statute imposing the tax,…