S & M Finance Co. Fort Dodge v. Iowa State Tax Commission

LeGRAND, Justice.

This is a de novo appeal challenging a decree holding certain sales of personal property exempt from the imposition of sales tax under chapter 422, Code of Iowa.

Plaintiff, an Iowa corporation, has for many years engaged in the business of making loans secured by liens on personal property. Defendants are the Iowa State *507Tax Commission and its individual members. In this opinion we refer to the defendants jointly as the commission.

The facts are substantially without dispute. The controversy centers around the sale by plaintiff of its loan security — which in every case was a…