Justice Stephen G. Breyer, who wrote the high court's unanimous decision, said the law is "unusually emphatic" in denying exemptions to refund deadlines. He said it appeared "that Congress decided to pay the price of occasional unfairness in individual cases . . . in order to maintain a more workable tax enforcement system."

The court overturned earlier decisions in favor of Scott of Kapaa and Marian Brockamp of Arizona. Both had won appeals court decisions in favor of refunds for taxes paid while they were mentally incompetent.

Scott, a former California attorney and liquor dealer, said he was affected by alcoholism when he paid the IRS $30,096 he didn't owe. He said he didn't discover the error until years after the deadline to file for a refund.

Brockamp said her 93-year-old father, Stanley McGill, was senile when he wrote the IRS a check for $7,000 instead of the $700 he owed. The error wasn't discovered until after his death, years after the deadline.

Scott's case was joined with Brockamp's after the Clinton administration disagreed with the appeals court rulings, and the case was argued before the Supreme Court in December.

Scott, who says he has conquered his problems with alcohol, has taken the Hawaii bar examination and wants to practice law on Kauai.