In Zimmer U.S. Inc. v. Gerregano, the Tennessee Court of Appeals held that a waiver agreement that extends the time for a taxpayer to receive a refund does not extend the statute of limitations to file a suit challenging a denial or deemed denial of a refund.1 This means that a taxpayer may need to file a suit challenging a deemed denial of a refund while “in ongoing conversations with the department” regarding a refund claim.
Reprinted from Tax Notes State, June 6, 2022, p. 985. To read the full article, download the PDF below.
- No. M2020-00171-COA-R3-CV, 2021 Tenn. App. LEXIS 285 (Tenn. Ct. App. July 19, 2021).