First National Bank of Ottumwa v. Bair

REYNOLDSON, Justice.

Plaintiff bank appealed to district court a franchise tax deficiency assessment confirmed by defendant director. The bank now appeals from a district court ruling upholding the assessment. We reverse and remand.

Most of the relevant facts are stipulated. The bank is a nationally chartered institution with its principal place of business at Ottumwa, Iowa. For all pertinent years it had an installment loan department. Before 1969 the bank recorded as income the entire amount of the interest on discounted notes on the date the loan was made.

The Comptroller of the Currency…