Sahadi

Accounting malpractice actions are governed by a two-year statute of limitations under Code of Civil Procedure section 339, subdivision l. Courts have construed the statute as requiring commencement of the suit no later than two years after the client discovered (or reasonably should have discovered) the accountant’s negligence, and has suffered actual injury resulting from that negligence. International Engine Parts, Inc. v. Feddersen & Co. (1995) 9 Cal.4th 606 [ 38 Cal.Rptr.2d 150 , 888 P.2d 1279 ] (Feddersen) concerned the accrual of the statute of limitations for an accountant’s negligent preparation of tax returns. The Supreme Court in Feddersen held that where the client, after being audited, is determined by the Internal Revenue Service (IRS) to owe additional taxes, the two-year statute of limitations does not commence—i.e., the client-taxpayer does not sustain actual injury—until the IRS has made a final determination that there is a tax deficiency. The case before us tests the limits of Feddersen. We must decide whether the statute of limitations for accounting malpractice (negligent preparation of income tax returns) commences at the conclusion of the audit,…