from the IRS, and then file a refund suit in the Court of Federal Claims or in a district court. See 28 U.S.C. §§ 1346(a)(1), 1491(a)(1). Alternatively, to avoid having to pay the assessment in question before pursuing a claim, the taxpayer may file a petition with the Tax Court. See Flora, 362 U.S. at 163, 80 S.Ct. 630 (describing Congress’s creation of “a system in which there is one tribunal for prepayment litigation and another for post-payment litigation”). With certain exceptions, if a taxpayer chooses the latter path, and files a petition with the Tax Court, he cannot later maintain suit in the Court of Federal Claims or in a district court to obtain a credit or refund for the same taxable year. IRC § 6512(a); see Smith v. United States, 495 Fed.Appx. 44, 48 (Fed.Cir.2012) (<HOLDING>); cf. Sun Chem. Corp. v. United States, No.
holding that the united states court of federal claims does not have jurisdiction over a new claim or a claim of different scope that was not previously presented and certified to the contracting officer for decision holding that because it fell within the exclusive jurisdiction of the united states court of international trade the united states court of federal claims lacked jurisdiction over a matter that was protested or protestable holding that the united states court of federal claims lacks jurisdiction over claims sounding in tort including fraud holding that the united states court of federal claims lacked jurisdiction over claims arising from the violation of a criminal statute holding that the court of federal claims correctly found that irc  6512a precluded it from exercising jurisdiction because the taxpayer had previously filed tax court petitions seeking redetermination of the same liabilities citing solitron devices v united states 862 f2d 846 848 11th cir1989