Tyler v. Iowa Department of Revenue
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Iowa may constitutionally deny an inheritance tax exemption for bequests to stepchildren when the marriage between parent and stepparent was dissolved before the stepparent’s death, while granting an exemption when the marriage was not dissolved.
The Supreme Court affirmed the judgment of the district court affirming the administrative ruling of the Iowa Department of Revenue denying an estate’s request for a tax refund. An administrative law judge rejected the decedent’s stepchildren’s protest challenging the denial of the tax refund on the ground that Iowa Code 450.1(1)(e)’s classification of stepchildren violated their equal protection rights under Iowa Const. art. I, 6. The district court affirmed the Department’s decision. The Supreme Court affirmed, holding that section 450.1(1)(e) does not violate article I, section 6 of the Iowa Constitution because a rational basis exists for the legislature to exclude stepchildren postdivorce from the inheritance tax exemption for surviving spouses lineal descendants, lineal ascendants, and other stepchildren.
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