¶1CONCURRING OPINION BY
¶2I join in the analysis of the well-reasoned majority opinion, but write separately to emphasize two points. First, I do not read this opinion to suggest that statutes of repose are immune from a due process analysis, but only that 1) they are not subject to equitable tolling and 2) the statute of repose involved here passes muster under the due process analysis set forth in Ciccarelli. Second, I believe the application of the three-year statute of repose in the lemon law context results in an unintended and inequitable consequence, but this result must be addressed by the General Assembly, not this court. Because the three-year limitation on filing refund requests is, on its face, both crystal clear and reasonable, this court must affirm the orders of the Board of Finance and Revenue.