Supreme Court of Missouri October 24, 1995, 77667 (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.