Hayes Drilling, Inc. v. Director of Revenue

ROBERTSON, Judge.

Hayes Drilling, Inc., (Hayes) elected to compute its state income tax in accordance with § 143.451.2, RSMo 1978, for its tax years ending February 28, 1981 and 1982. The Director of Revenue, following audit, assessed an additional tax of $880 for 1981 and $589 for 1982, on the basis that Hayes should have included 50 percent of the corporation’s income from transactions allegedly occurring partly in Missouri and partly in other states. Hayes sought review of the Director’s assessment in the Administrative Hearing Commission. After hearing, the Administrative Hearing…