CONOCO v. DEPT. OF REVENUE & FINANCE

90-1603.

477 N.W.2d 377 (1991)

CONOCO, INC., Appellant, v. IOWA DEPARTMENT OF REVENUE AND FINANCE, Appellee. SWISS VALLEY FARMS CO., Appellant, v. IOWA DEPARTMENT OF REVENUE AND FINANCE, Appellee.

Supreme Court of Iowa.

November 20, 1991.


Attorney(s) appearing for the Case

Richard A. Davidson of Lane & Waterman, Davenport, for appellants.

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

Considered by McGIVERIN, C.J., and HARRIS, LARSON, LAVORATO, and SNELL, JJ.


LAVORATO, Justice.

In this judicial review proceeding we must decide whether the language of Iowa Code section 422.73(2) (1981) allows a corporate taxpayer to file for a refund more than three years after the original deadline for filing its return. For reasons that follow, we hold that it does. We reverse the decision of the district court and remand with directions.

The facts of this case were stipulated and so are undisputed.

Conoco, Inc. and Swiss...

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