Same: Limitation

No refund shall be made unless written application therefor is filed with the tax collector within three

(3)years after payment was made; provided, however, if the refund claim is based upon an error made by the government of Guam resulting in an over assessment of the real property taxes on the property subject to the refund claim, the three

(3)year limitation period shall begin to run when the taxpayer discovers the government’s error or when the taxpayer is in possession of information that would put the taxpayer on reasonable notice to investigate whether the government has made an error, whichever occurs first.