Norfolk Holdings, Inc. v. Montana Department of Revenue

Norfolk Holdings, Inc., (Taxpayer) appeals from an order of the First Judicial District Court, Lewis and Clark County, holding that Taxpayer’s claim for a refund was barred by the statute of limitations. We affirm.

The sole issue raised on appeal is whether an automatic extension of time for filing corporate license tax returns may be included in computing the five-year limitations period in § 15-31-509(2), MCA.

Taxpayer reported its 1982 corporate license tax on a calendar year basis. On May 13,1983, it filed a tentative 1982 tax return form and paid $241,012 in estimated tax. At the same…