The Director of Revenue of Missouri (Director) appeals from an order of the Administrative Hearing Commission (AHC) denying
the Director's assessment of income tax, interest and penalties against Amway Corporation, Inc. (Amway) for the fiscal years
ending August 31 in 1978, 1979 and 1980. The questions presented are whether 15 U.S.C. § 381 or the United States
Constitution prohibit Missouri from imposing an apportioned net income tax on Amway. Reversed. Decisions of the AHC are to be upheld when authorized by law and supported by competent and substantial evidence upon the
whole record. § 621.193, RSMo 1986; Unitog Rental Serv. v. Director of Revenue, 779 S.W.2d 568, 569 (Mo. banc 1989).
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