Why not wait until the process plays
out and the rulings are in place?
Because the process takes years and even if he wins the state is likely to appeal which will take another 18 months or so.
In the meantime there is a Statute of limitations of three years. Which means that you can only claim erroneously paid taxes retroactively for three years.
To toll the Statute of limitations you must put in a protective claim now. Every quarter you delay, you’re losing out.
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