Supreme Court of Missouri / Jun 16, 2020
Dreyer Electric Co., LLC, Respondent, vs. Director of Revenue, Appellant.
Dreyer Electric Co., LLC, sought a sales tax refund for electrical equipment installed in a sawmill, claiming it was exempt as "replacement equipment" "used directly in the manufacturing process" under section 144.030.2(5). The Administrative Hearing Commission (AHC) found all disputed equipment exempt. The Director of Revenue appealed, arguing for a narrower interpretation of the exemption. The Missouri Supreme Court reversed the AHC's decision, reaffirming the broader "integrated plant doctrine" but remanding the case for the AHC to apply this doctrine to each type of replacement part or equipment individually, rather than grouping them.