Missouri Court of Appeals, Eastern District / Apr 22, 2025
Gregory F.X. Daly, in his official capacity as the Collector of Revenue for the City of St. Louis, Missouri, Appellant, v. Mary Anne Helmsing, Respondent.
Gregory F.X. Daly, the Collector of Revenue for the City of St. Louis, appealed a circuit court judgment that found Mary Anne Helmsing's income from several limited liability companies was not subject to the City's earnings tax. The Collector argued Helmsing was precluded from challenging the taxes due to failure to pay under protest and that her income was taxable. The appellate court affirmed, holding that Helmsing was not precluded from challenging the taxes and that her income as a non-active limited partner was not "earned" income subject to the City's earnings tax.