The Administrative Law Judge affirmed the Department’s penalty waiver denial. Taxpayer requested a penalty waiver from a late filed inheritance tax return on the basis that the COVID-19 pandemic resulted in unavoidable delays in filing. Under Iowa Code § 421.27(1)(c) (2020) (see Iowa Code § 421.27(1)(d) (2022)) late-filed returns are subject to a penalty unless the taxpayer meets one of the listed exceptions. The code offers no “good cause” exception form the penalty for late filed returns. Neither party appealed the proposed decision: therefore it became the Department’s final order under Iowa Administrative Code rule 701-7.17(8)(d).