Glenwood Cooperative, Inc. v. United States

BRYSON, Circuit Judge.

The issue in this tax case is whether appellant Glenwood Cooperative, Inc., filed its claim for a refund of taxes within the period specified in the pertinent statute of limitations. The Court of Federal Claims concluded that it did not. Glenwood Cooperative, Inc. v. United States, 32 Fed.Cl. 568 (1995). We agree, and we therefore affirm.

I

Glenwood is a Louisiana agricultural cooperative. Before 1983, Glenwood’s accounting period, for federal income tax purposes, ended on March 31 each year. In 1983, Glen-wood sought permission from the Internal Revenue Service to change…