David and Gale Collison v. Director of Revenue

Summary

The Court affirmed the Administrative Hearing Commission’s denial of the Collisons’ sales tax credit for a replacement vehicle. Although the Collisons were the grantors, trustees, and beneficiaries of the revocable trust that owned the replacement vehicle, Missouri law treats the trust as legally distinct from the individuals who created and controlled it. Because the Collisons personally owned the destroyed vehicle while the trust owned the replacement vehicle, they were not the same owner for purposes of the credit.