Missouri Public Service Co. v. Director of Revenue

ROBERTSON, Judge.

Taxpayer appeals from a decision of the Administrative Hearing Commission upholding a use tax assessment of the Director of Revenue. The issue is whether a substance known as “Rolfite” is a “fuel” within the meaning of Section 144.030.2(1), RSMo 1986, and therefore exempt from use tax. As this case involves the construction of revenue laws in this State, we have jurisdiction. Mo. Const, art. V, sec. 3. The decision of the Administrative Hearing Commission is reversed.

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Taxpayer Missouri Public Service Company is a Missouri corporation engaged in the manufacture of electrical…