Bates v. Director of Revenue

RENDLEN, Chief Justice.

James Bates appeals from the Administrative Hearing Commission’s dismissal of his challenge to a sales tax assessment by the Director of Revenue under Missouri’s successor liability statute, § 144.150, RSMo 1978.1 The statute provides in pertinent part that successors to a business must withhold from the purchase price an amount sufficient to satisfy any sales taxes not paid by a previous owner and if the successor fails so to do he risks liability for his predecessor’s delinquency.

Bates purchased the Manor Inn, a motel, restaurant and lounge complex, without satisfying…