Delta Air Lines, Inc. v. Director of Revenue

ROBERTSON, Judge.

Section 143.451.4, RSMo 1994, provides an apportionment formula for corporations that operate interstate transportation services. That apportionment formula uses mileage as the basis for determining the percentage of the corporation’s income that must be attributed to Missouri for Missouri income tax purposes. The Director of Revenue (“Director”) assessed Delta Air Lines, Inc. (“Delta”) Missouri income tax liability. The Director included Delta’s “bridge miles” — the miles Delta airplanes flew over Missouri without physically landing in or taking off from a facility in…