This Note examines Missouri’s use tax under a set of particularly interesting and complex circumstances. In the instant case, Fall Creek Construction Company, Inc. v. Director of Revenue, a corporation conducting business in several states owned a fractional interest in transient personal property that was part of a much larger interchange agreement. This case illustrates the breadth and effect of Missouri’s use tax, raises question about how fractional ownership and interchange agreements may affect the use tax analysis, and reflects the Missouri Supreme Court’s unwillingness to permit taxpayers to enjoy the advantages of ownership without also bearing the burdens associated with those benefits.

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