Arizona Department of Revenue v. Dougherty

OPINION

FELDMAN, Justice.

¶ 1 In this tax case we consider whether, as a prerequisite to participating in a class action asserting a claim for refund, each taxpayer must file an individual administrative refund claim with the Arizona Department of Revenue (“ADOR”). In addition, we must resolve the related issue of whether filing a class claim in an administrative procedure will toll the statute of limitations for all putative class members.

FACTS

¶ 2 Since 1979,1 the Arizona tax code has allowed a deduction from income for dividends received from Arizona corporations— those doing more than half…