[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"detail-sidebar-cat-1-en-105":3,"doc-seo-255950-105":53,"doc-detail-255950-en":127},{"code":4,"msg":5,"data":6},0,"success",[7,14,19,24,29,34,39,44,49],{"id":8,"doc_module":9,"doc_module_name":10,"category_name":11,"show_sort_weight":12,"slug":13},11,1,"Template","Presentations",90,"presentations",{"id":15,"doc_module":9,"doc_module_name":10,"category_name":16,"show_sort_weight":17,"slug":18},12,"Resumes",80,"resumes",{"id":20,"doc_module":9,"doc_module_name":10,"category_name":21,"show_sort_weight":22,"slug":23},14,"Invoices",70,"invoices",{"id":25,"doc_module":9,"doc_module_name":10,"category_name":26,"show_sort_weight":27,"slug":28},15,"Posters",60,"posters",{"id":30,"doc_module":9,"doc_module_name":10,"category_name":31,"show_sort_weight":32,"slug":33},16,"Social Media",50,"social-media",{"id":35,"doc_module":9,"doc_module_name":10,"category_name":36,"show_sort_weight":37,"slug":38},17,"Forms",40,"forms",{"id":40,"doc_module":9,"doc_module_name":10,"category_name":41,"show_sort_weight":42,"slug":43},18,"Letters",30,"letters",{"id":45,"doc_module":9,"doc_module_name":10,"category_name":46,"show_sort_weight":47,"slug":48},21,"Paper Templates",5,"papers-templates",{"id":50,"doc_module":9,"doc_module_name":10,"category_name":51,"show_sort_weight":4,"slug":52},158,"General","general-158",{"code":4,"msg":54,"data":55},"ok",{"site_id":56,"language":57,"slug":58,"title":59,"keywords":60,"description":61,"schema_data":62,"social_meta":120,"head_meta":122,"extra_data":124,"updated_unix":126},105,"en","keo-rental-llc-v-van-buren-county-board-of-review-october-3-2012-appellate-decision","Keo Rental, L.L.C. v. Van Buren County Board of Review - October 3, 2012 Appellate Decision","","A taxpayer protest addressed to the Iowa county board of review included a properly routed cover letter, but the enclosed petition concerned an unrelated property in another county. The court analyzes whether the defective filing substantially complied with Iowa Code section 441.37 (2009), focusing on whether the government’s “clerical error” exception can excuse late challenges. Because reasonable notice of protest grounds was not provided, the filing failed substantial compliance, summary judgment should have been granted, and the district court’s order was reversed.",{"@graph":63,"@context":119},[64,80,102],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":41,"@type":70,"position":76},"https://docshare.wps.com/template/letters/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/keo-rental-llc-v-van-buren-county-board-of-review-october-3-2012-appellate-decision/255950/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/keo-rental-llc-v-van-buren-county-board-of-review-october-3-2012-appellate-decision/255950.png","ImageObject",442,249,{"name":88,"@type":89},"Chloe Bennett","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-21","2026-09-13",true,{"@type":98,"interactionType":99,"userInteractionCount":101},"InteractionCounter",{"@type":100},"ViewAction",6,{"@type":103,"mainEntity":104},"FAQPage",[105,111,115],{"name":106,"@type":107,"acceptedAnswer":108},"What was the main issue on appeal in Keo Rental’s case?","Question",{"text":109,"@type":110},"Whether the taxpayer’s protest substantially complied with Iowa Code section 441.37 (2009) when the cover letter was correct but the enclosed petition related to an unrelated property in another county.","Answer",{"name":112,"@type":107,"acceptedAnswer":113},"Why did the court reject the “clerical error” exception?",{"text":114,"@type":110},"The statute allows late challenges under clerical error made by the government, not by the taxpayer. The exception did not apply to the taxpayer’s defective filing.",{"name":116,"@type":107,"acceptedAnswer":117},"What determined the outcome regarding substantial compliance?",{"text":118,"@type":110},"The original mailing did not give the board reasonable notice of the grounds for the taxpayer’s protest, so the requirements of section 441.37 were not substantially met and the board properly denied the protest.","https://schema.org",{"og:url":78,"og:type":121,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":123,"canonical":78},"index,follow",{"doc_id":125,"site_id":56},255950,1790183877,{"code":4,"msg":5,"data":128},{"doc_id":125,"user_id":129,"nickname":88,"user_avatar":130,"doc_module":9,"category_id":40,"category_name":41,"doc_title":59,"doc_description":61,"doc_content":131,"file_id":132,"file_url":133,"file_type":134,"file_size":135,"view_count":101,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":8,"language":136,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":137,"faqs":138,"seo_title":139,"seo_description":61,"update_tm":140,"read_time":79},962084925782,"https://ap-avatar.wpscdn.com/davatar_9964176cb1d06d4a9deccf72a44ae3dc","IN THE COURT OF APPEALS OF IOWA  \nNo. 2-828 / 11-1544  \nFiled October 3, 2012  \nKEO RENTAL, L.L.C.,  \nPetitioner-Appellee,  \nvs.  \nVAN BUREN COUNTY BOARD  \nOF REVIEW,  \nRespondent-Appellant.  \nAppeal from the Iowa District Court for Van Buren County, Joel D. Yates , Judge.  \nThe Van Buren County Board of Review appeals a district court’s ruling denying summary judgment in a taxpayer protest. REVERSED.  \nJamie L. Cox and Frank W. Pechacek, Jr. of Willson & Pechacek, P. L.C. , Council Bluffs, for appellant.  \nSteven Gardner of Denefe, Gardner & Zingg, P.C. , Ottumwa, for appellee.  \nHeard by Eisenhauer, C.J. , and Doyle and Tabor, JJ.  \nTABOR, J.  \nIn this appeal, we must determine whether a taxpayer’s protest that included a cover letter addressed to the county board of review listing the property at issue, but enclosed a petition involving an unrelated property in another county substantially complied with the filing requirements in Iowa Code section 441.37 (2009) . After the board refused its protest, the taxpayer appealed to the district court, which ruled the error was “clerical in nature” and directed the board to consider the late filing.  \nBecause the statute permits late challenges when clerical errors are made by the government but not the taxpayer, the “clerical error” exception does not save the defective filing. Because nothing in the original mailing provided the board with reasonable notice of the grounds for the taxpayer’s protest, it did not substantially comply with section 441.37 and was properly denied by the board. Accordingly, the district court should have granted the board’s motion for summary judgment.1  \nI. Background Facts and Procedures  \nIn March 2009 , the Van Buren County Assessor assessed property located in Van Buren County and owned by Keo Rental , L. L.C. Keo Rental intended to protest the tax assessment. Counsel prepared a letter and petition to  \n1 Generally, the denial of summary judgment is interlocutory. McCubbin Seed Farm, Inc.  \nv. Tri-Mor Sales, Inc. , 257 N.W.2d 55, 57 (Iowa 1977); see also Griffin Pipe Prods. Co., v. Bd. of Review, 789 N.W.2d 769, 770 (Iowa 2010) . Here, the board filed a notice of appeal instead of seeking permission to appeal in advance of final judgment. The taxpayer does not challenge the board’s right to appeal. We opt to consider the jurisdictional question addressed by the district court under the flexible standard in Iowa Rule of Appellate Procedure 6.108.  \nsend to the Van Buren County Board of Review on behalf of his client, Keo Rental. He also prepared a similar letter and petition regarding a protest to Davis County regarding that county’s assessment of property belonging to a separate client, MC Holdings, L. L.C.  \nAlthough the cover letters for both taxpayers were sent to the correct counties, the petitions were inadvertently switched. The Van Buren County Board of Review received Keo Rental’s letter, but a petition for MC Holdings’property. The Davis County board received MC Holdings’ letter, but a petition for Keo Rental’s property in Van Buren County. Both petitions were postmarked on May 5, 2009, the statutory deadline for filing a protest. The Van Buren County board sent a letter to Keo Rental’s attorney on May 11 explaining that because the relevant property was located in Davis County, the board had no jurisdiction over the property, and therefore could take no action on the protest. On May 19, Davis County denied Keo Rental’s protest.  \nThree days later, Keo Rental filed an “Application for Reconsideration”with the Van Buren County Board of Review, requesting the board consider the Van Buren County property petition inadvertently sent to the Davis County board. The Van Buren County Board of Review denied the request on May 28, reasoning that because the filing was beyond the statutory deadline, allowing the request “would be opening the door to other protests that may not be timely filed or invalid.”  \nIn June 2009, Keo Rental appealed the 2009 a","cbCain7eVNYTEFAT","https://ap.wps.com/l/cbCain7eVNYTEFAT","pdf",148274,"English","# Facts and Procedures\n# Scope and Standard of Review\n# Substantial Compliance Analysis","[{\"question\":\"What was the main issue on appeal in Keo Rental’s case?\",\"answer\":\"Whether the taxpayer’s protest substantially complied with Iowa Code section 441.37 (2009) when the cover letter was correct but the enclosed petition related to an unrelated property in another county.\"},{\"question\":\"Why did the court reject the “clerical error” exception?\",\"answer\":\"The statute allows late challenges under clerical error made by the government, not by the taxpayer. The exception did not apply to the taxpayer’s defective filing.\"},{\"question\":\"What determined the outcome regarding substantial compliance?\",\"answer\":\"The original mailing did not give the board reasonable notice of the grounds for the taxpayer’s protest, so the requirements of section 441.37 were not substantially met and the board properly denied the protest.\"}]","Keo Rental, L.L.C. v. Van Buren County Board of Review - October 3, 2012 Appellate Decision | PDF",1789296171]