Wolff Shoe Co. v. Director of Revenue

GARY M. GAERTNER, Special Judge.

This is an appeal from a final decision of the Administrative Hearing Commission involving the construction of the revenue laws of the State of Missouri. This Court has exclusive jurisdiction. Mo. Const. art. V, § 3. The sole issue presented is whether § 144.010.1(7), RSMo 1986, excludes income from appellant’s sales, in which both the shipping point and the destination point are outside Missouri, from the numerator of the single factor formula contained in § 143.451.2(2), RSMo 1986. The Administrative Hearing Commission held § 144--010.1(7) is not binding when…