In Van Dyke v. Dunker & Aced (1996) 46 Cal. App. 4th 446, the plaintiffs claimed they donated property in reliance on their accountant's erroneous advice that they would receive a full tax deduction. Later, the accountant told the plaintiffs they could claim only a partial deduction and filed a return claiming only the lesser amount. The ultimate amount allowed was not determined until still later, as a result of negotiations between the plaintiffs' new tax preparer and the IRS. The plaintiffs contended they did not suffer actual injury until the IRS finally determined the amount of the deduction. (Van Dyke, supra, 46 Cal. App. 4th at p. 452.) The court, however, held that "the Feddersen rule [International Engine Parts, Inc. v. Feddersen & Co. (1995)] was expressly limited to a specific type of accountant malpractice; i.e., 'the negligent preparation of tax returns.' " ( Id. at p. 454.) The alleged malpractice in Van Dyke was not negligent tax return preparation but the erroneous tax advice upon which the plaintiffs had relied to their detriment. (Ibid.) The court therefore concluded that the plaintiffs suffered actual injury, and the statute of limitations began to run, either when the plaintiffs donated the property in reliance on the erroneous tax advice or when they filed their return and paid taxes in excess of the amount they expected to pay. ( Id. at p. 455.) In Van Dyke, the reliance occurred when the plaintiffs donated the property. The court held the plaintiffs sustained actual injury either at that point or when they filed their return after discovering the error and suffered out-of-pocket losses by paying more taxes than they had expected to pay. (Van Dyke, supra, 46 Cal. App. 4th at p. 455.)