Carter-Lanhardt, Inc. v. District of Columbia

KERN, Associate Judge:

These appeals present for our determination the issue of how long a taxpayer seeking a refund from the District of Columbia may wait before filing a claim in the Tax Division of the Superior Court. More specifically, we are asked to decide which of two statutory periods of limitations governs such a claim. The taxpayers in the instant case argue that the general three-year statute of limitations contained in D.C.Code 1973, § 12-301(8) governs their appeals to the trial court for refunds of taxes. The Corporation Counsel, on behalf of the District, argues instead that the…