Section 15 Entitlement to Apportionment of Income vs. Application of the Apportionment Formula
| Library | Tax Law 2009 |
The threshold question of entitlement to apportionment of income is separate and distinct from application of the apportionment formula to particular transactions. Foley-Belsaw Co. v. Dir. of Revenue, No. RI-83-1985, 1986 WL 23198 (Mo. Admin. Hearing Comm’n, Sept. 12, 1986). A taxpayer could be entitled, theoretically, to apportion its income by reason of its employment of labor and capital outside Missouri, but nonetheless find that all of its transactions are viewed as wholly within Missouri.
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- Dick Proctor Imports, Inc. v. Dir. of Revenue State of Mo., No. RI-85-1561...
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