Aloe Vera of America, Inc. v. United States

Opinion by Judge THOMAS;

Partial Concurrence and Partial Dissent by Judge WALLACE.

OPINION

THOMAS, Circuit Judge:

This appeal presents the question, among others, of what event triggers the running of the statute of limitations for a claim for wrongful disclosure of a tax return pursuant to 26 U.S.C. § 7431(d). We conclude that the statute of limitations begins to run when the plaintiff knows or reasonably should know of the government’s allegedly unauthorized disclosures. We also conclude, in the circumstances presented by this case, that the statute of limitations did not begin to run when the…