Legal Opinion
Citibank, N.A. v. South Dakota Department of Revenue
South Dakota Supreme Court
Decided July 29, 2015No. 26933PublishedCited by 13 opinions
1Opinion of the Court
WILBUR, Justice.
[¶ 1.] Citibank, Inc. (“Citibank”) filed a tax refund claim with the South Dakota Department of Revenue in 2012 requesting a return of a portion of bank franchise taxes paid for the tax years 1999, 2000, 2001, and 2002. The Department of Revenue denied the tax refund claim. Citibank requested a hearing with the Office of Hearing Examiners (“OHE”). OHE found that the refund claim was time-barred by the three-year statute of limitations contained in SDCL 10-59-19. Consequently, OHE dismissed the case for lack of jurisdiction. The circuit court affirmed OHE. Citibank appeals. We…
2Cases cited44 opinions
- Arbaugh v. Y & H Corp.Supreme Court of the United States · 2006
- Holland v. FloridaSupreme Court of the United States · 2010
- Irwin v. Department of Veterans AffairsSupreme Court of the United States · 1991
- McKesson Corp. v. Division of Alcoholic Beverages and Tobacco, Fla. Dept. of Business RegulationSupreme Court of the United States · 1990
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
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3Cited by13 opinions
- In re Declaratory Ruling re SDCL 62-1-1(6)South Dakota Supreme Court · 2016
- Estate of SmeenkSouth Dakota Supreme Court · 2022
- Jans v. Department of Public SafetySouth Dakota Supreme Court · 2021
- Application of Black Hills PowerSouth Dakota Supreme Court · 2016
- Hallberg v. S.D. Board of RegentsSouth Dakota Supreme Court · 2019
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