Under Missouri law, sales are sourced
for local tax purposes based on origin but, as a safeguard, no purchase made from an out-of-state seller may be subject to a higher tax burden than a similar purchase made from within a taxpayer's local jurisdiction.
The SPOCI portion is sourced
under the general SPOCI rules and the remainder in accordance with Treas.
If a sale, the income would be sourced
to the place where title to the property passes to the buyer.
Instead, it concluded that such fees should be sourced
as if they were interest, even though they were not actually interest.
Prior to 1987, taxpayers that derived income from the sale of personal property sourced
such income under the "title passage" rule.