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DZIURA v. U.S.

No. 98-1889.

168 F.3d 581 (1999)

Bruce DZIURA and Ann Dziura, Plaintiffs, Appellants, v. UNITED STATES of America, Defendant, Appellee.

United States Court of Appeals, First Circuit.

Decided February 26, 1999.

Attorney(s) appearing for the Case

Gerald Glasser, with whom Kalill, Glasser and Associates was on brief, for appellants.

Sara Ann Ketchum, Attorney, Tax Division, United States Department of Justice, with whom Loretta C. Argrett, Assistant Attorney General, Donald K. Stern, United States Attorney, and Jonathan S. Cohen, Attorney, Tax Division, were on brief, for appellee.

Before SELYA, STAHL and LIPEZ, Circuit Judges.

SELYA, Circuit Judge.

This appeal pivots on the accrual date for the two-year statute of limitations applicable to certain actions against the Internal Revenue Service (IRS). We hold that the taxpayers' cause of action accrued more than two years before the date of suit. Consequently, we affirm the district court's dismissal of the taxpayers' complaint.

The events that gave rise to this action paint an interesting...

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