International Engine Parts, Inc. v. Feddersen & Co. (1995) 9 Cal. 4th 606, did not say there could never be actual injury in fact until the IRS assessed a deficiency. To the contrary, the court expressly acknowledged that "obviously, in some cases injury will be clear before the notice of deficiency is given to the taxpayer." (Feddersen, supra, 9 Cal. 4th 606, 621, ) Notwithstanding that acknowledgment, the court concluded that "uniformity in application serves a more important function when interpreting statutes of limitation than does the identification of the precise point at which some harm might be said to have occurred . . . ." ( Id. at pp. 621-622.) Therefore, it held the triggering event should be the deficiency assessment, because use of that date "provides the parties with a bright line that, once crossed, commences the limitations period under section 339, subdivision 1, and therefore provides certainty in terms of the statute's application." ( Id. at p. 621.) Thus, it appears the Feddersen court based its holding not on a conclusion that no actual injury occurs until there is a final IRS assessment, but on its determination that in the context of negligent tax return preparation, the need for uniformity overrides the usual considerations that dictate when the statute of limitations should be deemed to commence. Not surprisingly, therefore, subsequent decisions have given Feddersen's bright-line holding only narrow application.