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Case No. 16-1731

Paula J. Tyler and Mark J. Alcorn
Iowa Department of Revenue

Paula J. Tyler and Mark J. Alcorn appeal the district court’s judicial review ruling that affirmed the Department of Revenue’s denial of their request for a $202,705 refund of inheritance tax based on the unconstitutionality of Iowa Code section 450.1(1)(e). The appellants argue that section 450.1(1)(e) violates the Iowa Equal Protection Clause because it makes a distinction between stepchildren whose parent and stepparent divorce prior to the decedent-stepparent’s death and stepchildren whose biological parent dies before the decedent-stepparent’s death. In other words, if the natural parent dies during the marriage and the stepchildren inherit from their stepparent, their inheritance is exempt.

Trial Court Case No.:


Paula J. Tyler and Mark J. Alcorn


Iowa Department of Revenue

Attorneys for the Appellant

David J. Dutton
Ekrich D. Priebe

Attorneys for the Appellee

Donald D. Stanley
Hristo Chaprazov

Supreme Court

Oral Argument Schedule


Sep 20, 2017 1:30 PM


Supreme Court Opinion

Opinion Number:
Date Published:
Nov 17, 2017
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