Iowa Code

Iowa Code § 633.32 (2026)

Delinquent inventories and reports

✓ current as of July 2026

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1. On June 1 and December 1 of each year, the clerk shall notify the fiduciary and the fiduciary’s attorney of any delinquent inventories or reports due by law in any pending estate, trust, guardianship, or conservatorship, and that unless such delinquent inventory or report is filed within sixty days thereafter, the matter shall be reported to the presiding judge. If the delinquent inventory is not filed within the time so specified, the fiduciary will be subject to removal under the provisions of section 633.65 of this Code.

2. On August 1 and February 1 of each year, the clerk shall report to the presiding judge all delinquent inventories or reports in estates, trusts, guardianships, or conservatorships on which such notice has been given and no report or inventory has been filed in response to the notice.

3. The reports required by this section shall indicate thereon all cases in which the attorney, or the fiduciary or the fiduciary’s surety, is deceased, or insolvent, or cannot be found, or has removed from this state, and where it is shown by said reports, or it otherwise appears that there are no known assets belonging to the estate, the judge may, on the judge’s own motion, order said estate closed, and may, in the judge’s discretion, waive costs, or, on reasonable notice to the fiduciary, tax costs against the fiduciary. Such order shall not operate to prevent the reopening of such estate. [C97, §3269; C24, 27, 31, 35, 39, §11845; C46, 50, 54, 58, 62, §632.14; C66, 71, 73, 75, 77, 79, 81, §633.32] 2000 Acts, ch 1150, §1\n\n PART 3 PROCEDURE IN PROBATE \n

Notes of Decisions

Cited in 35 cases (1 in the last 5 years), 1948–2023 · leading case: Iowa Supreme Court Attorney Disciplinary Bd. v. Lickiss, 786 N.W.2d 860 (Iowa 2010).

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Iowa Supreme Court Attorney Disciplinary Bd. v. Lickiss, 786 N.W.2d 860 (Iowa 2010). · cites it 4× “See Iowa Code § 633.32 (2005) (requiring clerk of court to report delinquent inventories and reports to the presiding judge); Iowa Ct.”

Comm. on Prof'l Ethics & Conduct of the Iowa State Bar Ass'n v. Bitter, 279 N.W.2d 521 (Iowa 1979). · cites it 4× “The other item of alleged neglect arose out of the undisputed fact that as of July 1, 1977, respondent had 26 probate matters which were in a state of "delinquency" under section 633.32, The Code, and concerning which he had previously been sent notices to cure.”

Iowa Supreme Court Attorney Disciplinary Bd. v. Rickabaugh, 728 N.W.2d 375 (Iowa 2007). · cites it 2× “As a result, the estate accrued over $3000 in penalty and interest. Moreover, Rickabaugh’s neglect delayed the administration of all three estates and required the executors of each estate to hire a new attorney.”

Comm. on Prof'l Ethics & Conduct of the Iowa State Bar Ass'n v. Minette, 424 N.W.2d 459 (Iowa 1988). · cites it 8× “See Iowa Code § 633.32 (1985); Iowa R.Prob.P.”

Iowa Supreme Court Bd. of Prof'l Ethics & Conduct v. Sather, 534 N.W.2d 428 (Iowa 1995). · cites it 4× “Sather did not file the report and as a result, in January of 1991, the clerk reported the delinquency pursuant to Iowa Code section 633.32 (1989) and Iowa Rule of Probate Procedure 5.”

Comm. on Prof'l Ethics & Conduct of the Iowa State Bar Ass'n v. Rogers, 313 N.W.2d 535 (Iowa 1981). · cites it 2× “In addition, the Commission observed that Rogers had been unresponsive to the *536 Committee’s requests and to the clerk’s notices of delinquencies posted to him pursuant to section 633.32, The Code 1973, 1975, 1977, 1979 and Iowa S.”

Comm. on Prof'l Ethics & Conduct of the Iowa State Bar Ass'n v. Winkel, 415 N.W.2d 601 (Iowa 1987). · cites it 4× “See Iowa Code §§ 633.32 , 633.-361, 633.363 (1987).”

Comm. on Prof'l Ethics & Conduct of the Iowa State Bar Ass'n v. Rosene, 412 N.W.2d 634 (Iowa 1987). · cites it 4× “See Iowa Code § 633.32 (1). The delinquencies in both estates were identical: Rosene failed to obtain an income tax release in each estate and failed to close the estates within the time allowed by law.”

Iowa Supreme Court Bd. of Prof'l Ethics & Conduct v. Erbes, 604 N.W.2d 656 (Iowa 2000). · cites it 4× “See Iowa Code § 633.32 (1). In each case the Board charged Erbes with neglect of a client’s legal matter, in violation of DR 6-101(A)(3).”

Comm. on Prof'l Ethics & Conduct of the Iowa State Bar Ass'n v. Paulos, 410 N.W.2d 260 (Iowa 1987). · cites it 2× “See Iowa Code § 633.32 (1985); Iowa R. of Prob.”

Comm. on Prof'l Ethics & Conduct of the Iowa State Bar Ass'n v. Bromwell, 389 N.W.2d 854 (Iowa 1986). · cites it 2× “See Iowa Code § 633.32 ; Iowa Sup. Ct. Prob. R.”

Iowa Supreme Court Bd. of Prof'l Ethics & Conduct v. Waples, 677 N.W.2d 740 (Iowa 2004). · cites it 2× “On July 1,1998, the clerk of court issued a notice under Iowa Code section 633.32 advising the executors and Waples that they were delinquent in filing an interlocutory report due within eighteen months of the second publication of notice to creditors.”

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— Iowa Code § 633.32(2) — 2 cases

Comm. on Prof'l Ethics & Conduct of the Iowa State Bar Ass'n v. Rosene, 412 N.W.2d 634 (Iowa 1987). “See Iowa Code § 633.32 (1). The delinquencies in both estates were identical: Rosene failed to obtain an income tax release in each estate and failed to close the estates within the time allowed by law.”

Iowa Supreme Court Bd. of Prof'l Ethics & Conduct v. Meyer, 574 N.W.2d 312 (Iowa 1998).

— Iowa Code § 633.32(3) — 2 cases

Iowa Supreme Court Bd. of Prof'l Ethics & Conduct v. Winkel, 542 N.W.2d 252 (Iowa 1996).

Iowa Sup. Ct. Bd. v. Winkel, 542 N.W.2d 252 (Iowa 1996).

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