Electrolux Holdings, Inc. v. United States

MEMORANDUM OPINION AND FINAL ORDER

BRADEN, Judge.

This case presents the United States Court of Federal Claims with a question of first impression concerning the construction and application of 26 U.S.C. § 6511(d)(2)(A), a special exception to 26 U.S.C. § 6511(a), the general statute of limitations for filing a federal tax refund claim. For the reasons discussed herein, the court has determined that this special exception is not applicable in this case and, therefore, the Complaint must be dismissed for failure to comply with the jurisdiction prerequisite of filing a timely refund claim.

RELEVANT…