Davenport Bank & Trust Co. v. Iowa Department of Revenue & Finance

CARTER, Justice.

The appellant, Davenport Bank and Trust Company (the bank) challenges the district court’s order upholding the amount of franchise taxes assessed for the years 1982-85 inclusive. This judicial proceeding is for review of agency action as provided in Iowa Code section 17A.19 (1987). The respondent in the district court and appel-lee in this court is the Iowa Department of Revenue and Finance (the agency).

The bank argues that a portion of the franchise tax imposed by the agency for the years in question was (a) improperly imposed under applicable Iowa statutes, (b) precluded by…