Supreme Court of the United States February 22, 2000, 98-1667 (Baral v. United States)

Justice Thomas

delivered the opinion of the Court.

Internal Revenue Code § 6511(b)(2)(A) imposes a ceiling on the amount of credit or refund to which a taxpayer is entitled as compensation for an overpayment of tax: “[T]he amount of the credit or refund shall not exceed the portion of the tax paid within the period, immediately preceding the filing of the claim, equal to 3 years plus the period