California, United States of America
The following excerpt is from International Engine Parts, Inc. v. Feddersen & Co., 38 Cal.Rptr.2d 150, 888 P.2d 1279, 9 Cal.4th 606 (Cal. 1995):
How long after discovering a costly mistake in a federal income tax return may the taxpayer wait to bring a malpractice action against the accountant who prepared the return? For actions asserting malpractice by professionals other than attorneys or health care providers, Code of Civil Procedure section 339, subdivision 1, provides a two-year limitations period. In Budd v. Nixen (1971) 6 Cal.3d 195, 201, 98 Cal.Rptr. 849, 491 P.2d 433 (hereafter Budd ), this court decided that the two-year limitations period for professional malpractice actions begins to run upon discovery of the malpractice and the occurrence of "[a]ny appreciable and actual harm."
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