Lloyd v. Director of Revenue

HOLSTEIN, Judge.

In 1987, 1988 and 1989 Harry J. Lloyd and Patricia A. Lloyd filed Missouri individual income tax returns in which they apportioned income taxable to them as a result of the activity of five S corporations.1 Following a 1990 audit of those tax returns, the apportionment was disallowed and a notice of deficiency was issued. The Lloyds protested the director of revenue’s decision, but to no avail. The Lloyds then deposited the deficiency with the director and sought review of the decision before the circuit court of Cole County. § 143.-841.5, RSMo Supp.1992.2 The Lloyds appealed…