of their oil and gas interest for nonpayment of taxes was invalid. In Oz Gas, supra, our High Court refused to apply IOGA retroactively to invalidate years of tax assessments on oil and gas. Trustees argue, however, that since the instant case involves a determination of whether an unlawful tax assessment can divest a landowner of his property, not a retroactive refund of taxes, Oz Gas is not controlling on the retroactivity issue. Trustees assert that the factors determining whether a decision should be retroactively applied, which were identified in Chevron Oil v. Huson, 404 U.S. 97, 92 S.Ct. 349, 30 L.Ed.2d 296 (1971), must be analyzed on a case-by-case basis. Appellants’ brief at 26-26 (citing Christy v. Cranberry Volunteer Ambulance Corps, Inc., 579 Pa. 404, 856 A.2d 43 (2004) (<HOLDING>). On the facts herein, Trustees contend that
recognizing due consideration to be given attorney general decisions especially in cases involving tpia holding that new rules of law apply to pending civil cases on direct appeal regardless of whether events predate announcement of rule recognizing that generally pennsylvania applies decisions involving changes in the law in civil cases retrospectively le to cases pending on appeal holding that strickland applies to cases involving successive representation holding that 60day time limit for notice of appeal in civil cases not 10day limit in criminal cases applies to  2255 proceedings