ADAMS, Judge.
In 2001, McKesson Information Solutions, LLC filed an amended 1997 federal income tax return, which eventually was reviewed and approved by the Internal Revenue Service (IRS), and the IRS issued McKesson a refund of almost $12 million. But when McKesson sought a corresponding refund of $409,531 from Georgia, the State denied the claim on the ground that it was barred by the applicable three-year statute of limitation and not within the scope of any extension...
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