TERNUS, Justice.
The appellant, Iowa Department of Revenue, refused to credit an overpayment of 1996 income taxes to the 1997 tax obligation of the appellee taxpayers, Randall and Sherri Lange, due to the late filing of their 1996 tax return. The Langes claimed they mailed their 1996 return by the due date in 1997, and therefore, pursuant to Iowa Code section 622.105 (2001), their return should be deemed filed as of the date of mailing, even though it was not received...
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