Supreme Court of Missouri April 20, 1993, No. 75179 (Lloyd v. Director of Revenue)

lead-opinion

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.