Edwin Allen III and Melissa D. Allen v. Dallas County Board of Review

Summary

The Iowa Supreme Court reviewed a dispute over the Dallas County Board of Review’s dismissal of the Allens’ property-tax assessment protest. The court held that the taxpayers’ petition was sufficient to invoke the Board’s subject matter jurisdiction and that the Board had authority to consider a request to amend the petition to address the later assessment year. It affirmed the court of appeals, reversed the district court’s judgment, and remanded the case.

Holdings

1. The Allens' petition was sufficient to invoke the Board's subject matter jurisdiction and bring the protest within the class of cases the Board was authorized to review under Iowa's assessment-protest statutes.
2. The Board had authority to entertain a request to amend the petition and relate the amendment back to the original filing.
3. The Board abused its discretion by failing to exercise its discretion to consider the Allens' amendment request.

Questions Presented

1. Whether the Allens' petition was sufficient to invoke the Board of Review's subject matter jurisdiction despite identifying the 2011 assessment in a 2012 filing.
2. Whether the Board of Review had authority to entertain a request to amend the petition and relate the amendment back to the original filing.
3. Whether the Board abused its discretion by failing to exercise discretion regarding the Allens' request to amend their protest.

Disposition

reversed_and_remanded