Albemarle Corp. & Subsidiaries v. United States

BRYSON, Circuit Judge.

Albemarle Corporation and Subsidiaries (“Albemarle”) appeals from a final judgment of the Court of Federal Claims dismissing its complaint for a refund of certain taxes paid in the 1997 and 1998 tax years. The court held that it lacked subject matter jurisdiction over Albemarle’s claims because Albemarle had not filed its refund claims within the 10-year limitations period prescribed in 26 U.S.C. § 6511(d)(3)(A). We affirm.

I

In 1996, a Belgian subsidiary of Albe-marle issued 20-year debentures to Albe-marle and certain of its U.S. subsidiaries. Interest payments were made…