"How many days are in a year? The answer is more complicated than it may first appear. According to the Royal Observatory in Greenwich, the astronomically correct answer is approximately 365.24237 days. See Leap Years and Leap Seconds, Royal Observatory, http://www.nmm.ac.uk/explore/astronomy-and-time/time-facts/leap-years (last visited June 4, 2011).

Since it would be impractical for our calendars to add 0.24237 days at the end of each year, we make up the difference by adding an extra day, February 29, every fourth year, which is known as "leap year." Id. This would solve the problem entirely if a natural year were actually 365.25 days. However, because the actual figure is slightly less at 365.24237 days, adding a full day every four years ends up overcompensating. Id. To correct this, the Gregorian calendar approximates the natural year at 365.2425 days. See Leap Years, Naval Oceanography Portal, http://www.usno.navy.mil/USNO/astronomical-applications/astronomical-information-center/leap-years (last visited June 4, 2011).

As a result, we omit leap year every 100 years, in years ending in "00," except once every 400 years. Id. Therefore, while the years 1600 and 2000 were leap years, the years 1700, 1800, and 1900 were not. Id."

There are a large number of leap year cases, in which one party or another argued that Leap Year Day changes the statute of limitations or some other timing. The real lesson, though, is not to push the timing so close that one day will make or break you.

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