106 S.Ct. 2440, 91 L.Ed.2d 110 (1986). In that case, the Court found that the state had no reasonable nondiscriminatory alternatives to the action it had taken. Oregon Waste, 511 U.S. at 101, 114 S.Ct. 1345 (discussing the holding in Maine v. Taylor). 6 . This prospective interpretation of the statute is, of course, subject to legislative modification, consistent with the limitations of the dormant Commerce Clause and other relevant constitutional provisions. 7 . In its discussion of due process requirements in McKesson, the Court indicated that the issue of meaningful backward-looking relief might not be present if the taxpayer had a genuine opportunity for predeprivation relief. Id. at 38-39, 110 S.Ct. 2238. See also Cambridge State Bank v. James, 514 N.W.2d 565, 569-71 (Minn.1994) (<HOLDING>). The Chapmans not only had, but availed
holding refund of discriminatory tax required because predeprivation remedy not clearly available for tax years at issue holding the conduct element satisfied where debtor earned income during the tax years at issue but did not make any estimated tax payments had inadequate or no withholdings and latefiled his tax returns holding that a tax refund claim must be dismissed if the principal tax deficiency has not been paid in full holding that taxpayer was still required to go through tax refund procedure despite facial constitutional challenge to state intangibles tax holding that state legislature should determine whether to cure discriminatory tax by enforcing tax as to all or forgiving tax in its entirety