In United States v. Clintwood Elkhorn Mining Co., 553 U.S. 1 (2008), coal companies sought to recover unconstitutionally collected taxes on their coal exports. Id. at 5-6. Because the tax code has a three-year statute of limitations and the Tucker Act has a six-year statute of limitations, the companies filed IRS refund claims for the three immediately preceding years and asserted claims under the Tucker Act to recover the taxes levied in the three years prior to those claims. Id. For the claims brought under the Tucker Act, the companies argued that the Export Clause of the Constitution was money mandating and therefore conferred Tucker Act jurisdiction. Id. at 9. But, rather than determine whether the Export Clause mandated return of improperly collected taxes, the Court ruled that the administrative tax refund process preempted any possible Tucker Act jurisdiction. See id. at 4, 9. The Court found that the companies were required to first file a timely administrative refund claim, even though the Government admitted that the taxes were collected in violation of the Export Clause. Id. at 9. The Court relied on the broad language in 26 U.S.C. 7422(a) to show that Congress meant the statute to have expansive reach, which included claims that could otherwise be characterized as Tucker Act claims. Id. at 7, 9-12. Thus, the Court held that the lower courts erred when they granted Tucker Act jurisdiction over the claims for the earlier three years of taxes. Id. at 14-15. The Court held that I.R.C. 7422(a) barred coal companies from filing suit against the United States in the U.S. Court of Federal Claims ("CFC") for a refund of taxes that the United States levied on shipments of coal exports in violation of the Export Clause. 553 U.S. at 4, 128 S.Ct. 1511. The Court explained that the CFC lacked jurisdiction because the coal companies failed to first seek an administrative refund from the IRS as required by 7422(a). Id. Recognizing that the statute of limitations in the Internal Revenue Code had run, the coal companies filed suit in the CFC, asserting that the Tucker Act's more generous statute of limitations applied to their refund suit. Id. at 6, 128 S.Ct. 1511. Under the Internal Revenue Code's statute of limitations, a taxpayer seeking a tax refund must file a claim within three years of filing a return or within two years of paying the tax, whichever is later. See I.R.C. 6511(a). In contrast, the Tucker Act required a party to file a claim in the CFC "within six years after such claim first accrues." 28 U.S.C. 2501. The Court held that the plain meaning of I.R.C. 7422(a) demonstrated that Congress required a party seeking a tax refund for any reason to follow the same procedure-filing a refund claim first with the IRS. Clintwood Elkhorn, 553 U.S. at 4, 7-9, 128 S.Ct. 1511.