CARTER, Justice.
In consolidated appeals, Shell Oil Company (Shell) appeals a district court order upholding the constitutionality of an Iowa statute denying deductibility of certain federal excise taxes in computing Iowa corporation income tax liability; the Iowa Department of Revenue (IDOR) appeals a companion decision limiting the application of that statute. Both appeals involve the effect of a statute currently codified as Iowa Code section 422.35(10) (1987)...
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