Armstrong's, Inc. v. Iowa Department of Revenue

SCHULTZ, Justice.

This appeal involves the interpretation of section 422.25(2), The Code, which imposes a *625penalty on a taxpayer who fails to file a timely income tax return unless such failure is due to “reasonable cause.” The principal issue is whether a taxpayer’s reliance on a certified public accounting firm’s assurances that it would either file the taxpayer’s income tax return before the due date or file a request for an extension of time to file constitutes reasonable cause. On judicial review, the district court reversed an agency decision and held that such reliance constitutes…