Petitioner, a qualified subchapter S subsidiary financial institution, requested a Declaratory Order to determine whether a gain realized by the parent company of Petitioner from the sale of Petitioner should be included in the calculation of Petitioner's net income for franchise tax purposes under Iowa Code section 422.61(3). The Director found that the gain realized from the parent company's sale of Petitioner is not included in the calculation of Petitioner's net income for franchise tax purposes.