Eilian v. Dir. of Revenue
Annotate this CaseThe Director of Revenue determined that Jonathan Eilian underpaid his 2006 Missouri taxes because he used his federal "net operating loss" (NOL) to offset income that was taxable under Missouri law but not taxable under federal law. Eilian brought a complaint before the Administrative Hearing Commission challenging the Director's decision. The Commission ruled in favor of Eilian. The Supreme Court reversed, holding that Brown Group Inc. v. Administrative Hearing Commission was dispositive of the legal issues in this appeal and precluded Eilian from using his NOL to offset all of his Missouri-taxable income. Remanded to the Commission to recalculate Eilian's Missouri tax liability for 2006.
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