Ia 80 Group, Inc. And Subsidiaries, Formerly Known as Iowa 80 Truckstop, Inc. And Subsidiaries v. United States

SMITH, Circuit Judge.

Iowa 80 Group, Inc. (“Iowa 80”) operates multi-building truckstops in Walcott, Iowa, and Joplin, Missouri. The Internal Revenue Service (“IRS”) has categorized these facilities as retail convenience stores, which are depreciable over thirty years. Iowa 80 filed an amended tax return that sought a more favorable fifteen-year depreciation. It argued that its truckstops qualified for such depreciation because they are “retail motor fuels outlets”-based on the gross-revenues they generated from petroleum-based products. The IRS, however, rejected Iowa 80’s claim. Iowa 80 then…