Reich v. Collins, 513 U.S. 106, 9 (1994)

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114

REICH v. COLLINS

Opinion of the Court

test requirement. Under such a regime, taxpayers need not have taken any steps to learn of the possible unconstitutionality of their taxes at the time they paid them. Accordingly, they may not now be put in any worse position for having failed to take such steps.

For the reasons stated, the judgment is reversed and the case is remanded for the provision of " 'meaningful backward-looking relief,' " Harper, 509 U. S., at 101, quoting McKesson, 496 U. S., at 31, consistent with due process and our McKesson line of cases. See, e. g., Carpenter v. Shaw, 280 U. S. 363 (1930).

It is so ordered.

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