STREIT, Justice.
The Iowa Department of Revenue appeals from the district court ruling on judicial review reversing the agency's method of calculating interest on an assessment of Liberato and Dolores Iannones' income tax liability for their amended returns. Iannones claim the Department incorrectly interpreted the controlling statutory provisions of the Iowa Code in calculating the amount upon which interest shall accrue. Iannones contend the 1982 and 1983 overpayments...
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