Does this Court's holding in Return Mail, Inc. v. United States Postal Service, 139 S. Ct. 1853 (2019) overturn every case holding the Internal Revenue Service is a 'victim' entitled to restitution, and clarify that federal courts have no subject matter jurisdiction to order restitution in criminal tax cases?

QUESTIONS PRESENTED QUESTION 1 Does this Court’s holding in Return Mail, Inc. v. United States Postal Service, 139 S. Ct. 1853 (2019) overturn every case holding the Internal Revenue Service is a “victim” entitled to restitution, and clarify that federal courts have no subject matter jurisdiction to order restitution in criminal tax cases? QUESTION 2 Does a restitution order based on estimates rather than finally determined taxes render 26 US.C. § 6201(a)(4) unconstitutional, in that the statute bars criminal defendants from contesting IRS restitution assessments, depriving them of property ; without the due process afforded all other taxpayers?