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Missouri Revised Statutes

Mo. Rev. Stat. § 621.193 (2026)

Decision of commission to be upheld, when

✓ current as of May 2026
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  621.193.  Decision of commission to be upheld, when. — In cases reviewable under the provisions of section 621.189, the decision of the administrative hearing commission shall be upheld when authorized by law and supported by competent and substantial evidence upon the whole record, if a mandatory procedural safeguard is not violated and if the approval or disapproval of the exercise of authority in question by the administrative hearing commission does not create a result or results clearly contrary to that which the court concludes were the reasonable expectations of the general assembly at the time such authority was delegated to the agency.

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(L. 1978 S.B. 661)

Notes of Decisions
Cited in 120 cases (9 in the last 5 years), 1985–2023 · leading case: Sw. Bell Yellow Pages, Inc. v. Dir. of Revenue, 94 S.W.3d 388 (Mo. 2002).
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Sw. Bell Yellow Pages, Inc. v. Dir. of Revenue, 94 S.W.3d 388 (Mo. 2002). · cites it 6× “Section 621.193, RSMo 2000; Southwestern Bell Tel.”
Shelter Mut. Ins. Co. v. Dir. of Revenue, 107 S.W.3d 919 (Mo. 2003). · cites it 6× “(internal quotations omitted) (citing section 621.193, RSMo 2000; Southwestern Bell v.”
Buchholz Mortuaries, Inc. v. Dir. of Revenue, 113 S.W.3d 192 (Mo. 2003). · cites it 6× “The AHC ruled for Buchholz, ordering a refund of $101,565.17, after deducting sales tax on interments not intended to be permanent (.”
Shell Oil Co. v. Dir. of Revenue, 732 S.W.2d 178 (Mo. 1987). · cites it 6× “" Section 621.193, RSMo 1986. The Commission must observe mandatory procedural safeguards and its approval of the questioned agency action must not clearly create a result "contrary to .”
Cass Cnty. v. Dir. of Revenue, 550 S.W.3d 70 (Mo. 2018). · cites it 3× “banc 2015) (internal quotations omitted); see also § 621.193. Cass County argues the commission's decision is not authorized by law in that the director has no legal authority to withhold tax revenue owed to Cass County and redistribute the revenue to Lee's Summit.”
Wolff Shoe Co. v. Dir. of Revenue, 762 S.W.2d 29 (Mo. 1988). · cites it 2× “banc 1988); § 621.193, RSMo 1986. As well, we reiterate our adherence to the basic precept that tax statutes are to be strictly construed in favor of the taxpayer and against the taxing authority.”
Sw. Bell Tel. Co. v. Dir. of Revenue, 78 S.W.3d 763 (Mo. 2002). · cites it 3× “banc 2001); section 621.193, RSMo 2000. IV. Bell claims that its purchases, which include both new and replacement machinery and equipment, fall under section 144.”
Bartlett Int'l, Inc., & Bartlett Grain Co., L.P. v. Dir. of Revenue, 487 S.W.3d 470 (Mo. 2016). · cites it 3× “The decision of the AHC will be affirmed if it: (1) is authorized by law; (2) is supported by competent and substantial evidence upon the whole record; (3) does not violate mandatory procedural safeguards; and (4) is not clearly contrary to the reasonable expectations of the…”
House of Lloyd, Inc. v. Dir. of Revenue, 824 S.W.2d 914 (Mo. 1992). · cites it 4× “banc 1990); and § 621.193, RSMo 1986 provides the applicable standard of review of a final decision of the AHC decided pursuant to § 621.”
Psychiatric Healthcare Corp. v. Dep't of Soc. Servs., 100 S.W.3d 891 (Mo. Ct. App. 2003). · cites it 3× “In its first point, Hospital asks this court to rule that the circuit court correctly declared the Division’s regulation at 13 CSR 70-15.”
Burlington N. R.R. v. Dir. of Revenue, 785 S.W.2d 272 (Mo. 1990). · cites it 4× “banc 1989); § 621.193, RSMo 1986. Tax exemption provisions are to be strictly construed against the party claiming the exemption, Farm and Home Savings Ass'n.”
Sneary v. Dir. of Revenue, 865 S.W.2d 342 (Mo. 1993). · cites it 4× “and if the approval or disapproval of the exercise of authority in question by the administrative hearing commission does not create a result or results clearly contrary to that which the court concludes were the reasonable expectations of the general assembly at the time such…”
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