Task: Wrong Candidate Generation
Input (English): judgment of the Court, made clear that court decisions cannot be applied retroactively to civil causes already barred by statutes of limitation or res judicata. The Supreme Court has repeatedly affirmed the notion that a statute of limitation may bar a tax refund action, notwithstanding the Court’s ruling that the state’s taxing statute is unconstitutional, and irrespective of the Court’s retroactive application of that ruling. See McKesson Corp. v. Division of Alcoholic Beverages & Tobacco, Department of Business Regulation, 496 U.S. 18, 27, 45, 110 L. Ed. 2d 17, 29, 41, 110 S. Ct. 2238, 2245, 2254-55 (1990) (acknowledging that statutes of limitation may be dispositive in such cases); Ward v. Board of County Commissioners, 253 U.S. 17, 25, 64 L. Ed. 751, 759, 40 S. Ct. 419, 422 (1920) (<HOLDING>). See also United States v. Estate of Donnelly, 
 Holding statements: (A) holding that refund suit for tax imposed in violation of export clause filed beyond applicable period of limitations was barred where claimant had failed to first present timely administrative claim to internal revenue service even though there was little  if any  reason to believe that claim would have been granted (B) holding under section 7422a that the district court lacked jurisdiction over a taxpayers refund claim because the taxpayer failed to file a refund claim before the statute of limitations had run (C) holding that the taxpayer met the claim requirement where the taxpayer first filed a timely letter with the irs that requested a refund and subsequently filed a formal refund claim (D) holding statute of limitations should not be equitably tolled for taxpayer who filed a refund claim after the applicable statute of limitations (E) recognizing refund claim could be barred if there was any valid local limitations law in force when the claim was filed
Output (English): holding that refund suit for tax imposed in violation of export clause filed beyond applicable period of limitations was barred where claimant had failed to first present timely administrative claim to internal revenue service even though there was little  if any  reason to believe that claim would have been granted