South Dakota Supreme Court Bars Citibank Refund Claim Following IRS Audit Adjustment

Overview


Stephen Kranz called it “unfortunate” that the South Dakota Supreme Court denied a major bank’s refund claim for being past the statute of limitations, even though the bank was just informed by the IRS of a federal refund. He noted that “there are clear legal grounds for opening the statute of limitations to provide refunds after an IRS audit,” and labeled it “absurd” that the state contended a refund claim should be filed “before you even know that you have a refund to claim.”