The United States Supreme Court case, United States v. Marian Brockamp, Administrator of the Estate of Stanley B. McGill, Deceased (1996), centered on whether or not there should be an "equitable tolling" exception to the time limits for filing a tax refund claim under section 6511 of the Internal Revenue Code. The estate argued that due to mental illness and incompetency, they were unable to file within the prescribed period and thus requested leniency from these deadlines. However, in a unanimous decision led by Justice Stephen Breyer, it was ruled that Congress intended strict enforcement of this deadline without exceptions for equitable tolling when drafting Section 6511's detailed technical language regarding limitations periods for tax refund claims. Therefore, despite any extenuating circumstances such as mental incapacity or other disabilities preventing timely filing; no extensions would be granted beyond what is explicitly stated in law.

In the dissenting opinion for United States v. Marian Brockamp, Justice Stephen Breyer argued that the majority's interpretation of Section 6511 of the Internal Revenue Code was too rigid and failed to consider equitable tolling principles. He contended that Congress did not explicitly state in this section that it intended to preclude equitable tolling, a legal principle allowing courts to extend deadlines in exceptional circumstances. Furthermore, he pointed out several instances where other sections of tax law have been interpreted flexibly by courts despite similar language suggesting strict time limits. Therefore, he believed there should be room for exceptions based on fairness considerations within Section 6511 as well. In his view, denying taxpayers their refunds due to extraordinary circumstances beyond their control is fundamentally unfair and contrary to basic principles of justice.