Iowa 80 Group, Inc., and Subsidiaries, Formerly Known as Iowa 80 Truckstop, Inc. And Subsidiaries v. Internal Revenue Service

SMITH, Circuit Judge.

Iowa 80 Group, Inc., (“Iowa 80”) once again appeals the district court’s summary judgment order finding that its truckstop facilities failed to qualify as “retail motor fuels outlets,” and, thus, were not entitled to a fifteen-year depreciation schedule. In the first appeal, we concluded that Iowa 80’s facilities failed to meet the gross-revenues test, but remanded to the district court for consideration of whether the facilities qualified under a floor-space test. See IA 80 Group, Inc. and Subsidiaries v. United States, 347 F.3d 1067 (8th Cir.2003). On remand, the…