AOL LLC v. Iowa Department of Revenue

APPEL, Justice.

This case involves the question of whether the State of Iowa may impose sales tax on internet services provided by America Online, LLC (AOL) to its Iowa customers. The parties disagree as to whether the applicable administrative rule requires the origin and terminus of the communication to occur in Iowa in order for AOL’s gross receipts to be taxable and whether AOL’s service met this requirement. While the department found AOL subject to state sales tax, the district court and the court of appeals disagreed. For the reasons stated below, the decision of the court of appeals is…