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?

Does a restitution order based on estimates rather than finally determined taxes render 26 U.S.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?

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?