United States Ninth Circuit
Aloe Vera of Am., Inc. v. US, 10-17136
In taxpayers' suit claiming that the United States improperly disclosed tax information to the Japanese National Tax Administration (NTA) during the course of a joint investigation, district court's dismissal of some of the claims for lack of subject matter jurisdiction is: 1) reversed and remanded as to Count I where inquiry notice is not triggered by a single generalized event, but rather by the plaintiff's actual or constructive knowledge of each particular disclosure; and 2) affirmed as to the dismissal of Count II where it is barred by the statute of limitations.
Appellate Information
- Decided 11/15/2012
- Published 11/15/2012
Judges
- Thomas
Court
- United States Ninth Circuit