In TracFone Wireless, Inc. v. Director of Revenue, SC95785 (Mo. 2017), the Missouri Supreme Court recently held that an out-of-state seller of telecommunications services from Florida to customers in Missouri was not entitled to Missouri’s sales tax exemption for transactions made “in commerce” between Missouri and any other U.S. state.  In reaching its conclusion, the Court looked to the “true object” of the transactions to deem them purely local telecommunications service transactions, even though the seller was located outside of and the sales took place outside of Missouri.