Court of Appeals for the Eighth Circuit January 6, 2004, 02-3012 (Ia 80 Group, Inc. And Subsidiaries, Formerly Known as Iowa 80 Truckstop, Inc. And Subsidiaries v. United States)

SMITH, Circuit Judge.

Iowa 80 Group, Inc. (“Iowa 80”) operates multi-building truckstops in Walcott, Iowa, and Joplin, Missouri. The Internal Revenue Service (“IRS”) has categorized these facilities as retail convenience stores, which are depreciable over thirty years. Iowa 80 filed an amended tax return that sought a more favorable fifteen-year depreciation.