Courtney Lock


This Note examines the Supreme Court of Missouri’s holding in Miss Dianna’s School of Dance, Inc. v. Director of Revenue, ascertains the holding’s scope in light of recent statutory amendments, and explores whether Missouri sales tax is at a precipice going forward. Part II discusses the facts and holding of Miss Dianna’s School of Dance. Part III explores the Supreme Court of Missouri’s fluctuating interpretations of the statute. Part IV provides an indepth analysis of the Supreme Court of Missouri’s reasoning in Miss Dianna’s School of Dance and its relevance to the interpretation of the statute going forward, including an examination of Judge George W. Draper III’s dissent. Finally, Part V discusses the effect of recent statutory amendments, both on Miss Dianna’s School of Dance and on future cases involving amusement, entertainment, and recreation. This Note argues that both the court’s decision in Miss Dianna’s School of Dance and the subsequent statutory amendments to section 144.020 leave businesses in a more difficult position regarding whether to impose sales tax. Ultimately, this Note concludes that the future of the Missouri sales tax remains in doubt because of the ambiguity of the statutory enactment.

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