The Escher v. Woods case in 1929 revolved around the issue of whether or not a tax refund claim could be filed by an estate administrator after the death of a taxpayer, and if such claims were subject to statutes of limitations. The Supreme Court ruled that administrators can indeed file for refunds on behalf of deceased taxpayers, but these claims are still subject to time limits as outlined by law. In this particular case, it was determined that the claim had been filed too late and thus could not be considered valid. This decision clarified how laws regarding tax refunds apply in situations where the original taxpayer has passed away before filing their own claim.

In the dissenting opinion for Escher, Ancillary Administrator, et al. v. Woods, Treasurer of the United States, et al., Justice Stone argued that a tax refund claim should not be barred by statute of limitations if it was filed within two years after payment and before five years from filing return. He believed that this interpretation would align with Congress' intent when they enacted the Revenue Act of 1921 which provided taxpayers with an extended period to file claims in certain circumstances such as fraud or mistake in calculation. The majority's decision to bar the claim based on a strict reading of statutory language disregarded these special provisions and unfairly penalized taxpayers who acted diligently but were unable to meet rigid deadlines due to factors beyond their control.