Courtney M. Kay-Decker, Director, Iowa Department of Revenue v. Iowa State Board of Tax Review and Cable One, Inc.

MANSFIELD, Justice.

This administrative review proceeding requires us to decide whether a company providing Voice over Internet Protocol (VoIP) service on cable wires in Iowa is subject to central assessment as a “telephone company operating a line in this state” or, otherwise stated, a company “that ... operates ... any ... telephone line.” Iowa Code §§ 433.1, .12 (2007). In making this determination, we consider both the language of the statute and how it has been historically interpreted. Based on that review, we conclude that wiring installed originally for cable television purposes but…