In the case of Commissioner of Internal Revenue v. Robert F. Lundy, 1995, the Supreme Court ruled in favor of the IRS regarding a dispute over tax refund claims and jurisdictional timing issues. The issue at hand was whether or not a taxpayer could file for an additional refund claim after initially filing for one within a two-year period but before receiving any decision from the IRS on their initial claim. The court held that under section 6512(b)(3)(B) of the Tax Code, if no notice has been sent to taxpayers about their liability within two years prior to them filing suit in tax court, then they are only entitled to refunds attributable to taxes paid during those two years immediately preceding such filing date - regardless if they filed another claim afterwards or not.

In the dissenting opinion for Commissioner of Internal Revenue v. Robert F. Lundy, Justice Scalia disagreed with the majority's decision to remand the case back to lower courts due to jurisdictional issues related to a refund claim amount. He argued that this was unnecessary and would only result in further delays and complications without any substantial benefit or change in outcome. According to him, it was clear from existing laws that tax court had jurisdiction over cases involving disputed refunds regardless of their amounts, hence there was no need for additional clarification on this matter by lower courts. Furthermore, he criticized the majority’s interpretation of relevant statutes as overly rigid and literalistic which led them towards an incorrect conclusion about tax court’s jurisdictional limits.