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  5. 414 N.W.2d 113 (1987)
 

KELLY-SPRINGFIELD TIRE v. BD. OF TAX REV.

Nos. 87-278, 86-1565.

414 N.W.2d 113 (1987)

KELLY-SPRINGFIELD TIRE CO., Appellant, v. IOWA STATE BOARD OF TAX REVIEW, Appellee. SHELL OIL COMPANY, Appellant, v. The IOWA DEPARTMENT OF REVENUE, Appellee.

Supreme Court of Iowa.

October 21, 1987.

Attorney(s) appearing for the Case

Burns Mossman of Nyemaster, Goode, McLaughlin, Emery & O'Brien, P.C., Des Moines, for appellant Kelly-Springfield Tire Co.

J. Lloyd Kennedy and William D. Peltz, Houston, Tex. and James W. Hall of Hall & Irvine, Cedar Rapids, for appellant Shell Oil Co.

Thomas J. Miller, Atty. Gen., Harry M. Griger, Sp. Asst. Atty. Gen., and Gerald A. Kuehn, Asst. Atty. Gen., for appellee.

Considered en banc.

CARTER, Justice.

These consolidated appeals raise two legal issues in regard to income tax assessments by the Iowa Department of Revenue (IDOR) being judicially reviewed under Iowa Code section 17A.19 (1985). These issues are: (1) whether assessment of additional corporation income taxes by IDOR against appellant Kelly-Springfield Tire Co. (Kelly-Springfield) in No. 87-278 and appellant Shell Oil Company (Shell) in No. 86-1565, made more than three years after the...

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