In the case of Heiner v. Tindle, 1927, the U.S. Supreme Court ruled that a tax assessment could not be reopened after it had been closed and paid in full by taxpayers under an agreement with the Commissioner of Internal Revenue. The dispute arose when Mr. Tindle's estate was assessed for taxes based on gifts he made to his children before his death in 1919; these were considered part of his gross estate for taxation purposes under federal law at that time. However, this assessment was later challenged by Mr.Tindle’s executors who argued that those gifts should not have been included as they were made more than two years prior to his death - a provision allowed under Pennsylvania state law but not recognized federally until 1924 (after Tindle's death). The court sided with the executors stating reopening a settled matter would violate due process rights protected by Fifth Amendment.

In the dissenting opinion for Heiner v. Tindle, Justice Oliver Wendell Holmes Jr. argued that the majority's decision was inconsistent with previous rulings and principles of tax law. He believed that when a taxpayer makes a claim for refund based on an overpayment, it is their burden to prove not only that they have overpaid but also by how much. In this case, he felt the taxpayers had failed to meet this burden because they did not provide sufficient evidence to support their claim about the value of certain property at issue in calculating estate taxes owed after death. Therefore, he would have upheld the lower court's ruling denying them a refund.