AMANA SOCIETY SERVICE COMPANY

The Taxpayer appealed the Department's denial of a renewable energy tax credit based on a ten-year limitation period pursuant to Iowa Code section 476C.5 and Iowa Administrative Code rule 701—42.28. An Administrative Law Judge (ALJ) granted in part and denied in part both the Taxpayer's and Department's motions for summary judgment, finding the Department's rule was inconsistent with the statute and the statute controlled, enabling the taxpayer to claim the tax credit for calendar years 2018 and 2019 but not for calendar year 2020. Upon review, the Director adopted the ALJ's Proposed Summary Judgment Order and added that the Department's rule on the tax credit altered the meaning of the statute rather than interpreting it, exceeding its authority.