(“Had the plaintiffs filed [] a complaint [in the United States Court of Federal Claims for a tax refund], and had the plaintiffs been awarded a refund of the money levied from the bank accounts, as a result of this court’s proceedings, this court would have jurisdiction over the plaintiffs’ complaint for reasonable administrative and litigation costs.” (citing 26 U.S.C. § 7430(e)(4)(C)(ii))). The Tucker Act authorizes the United States Court of Federal Claims to adjudicate tax refund claims if a taxpayer has paid the full assessed federal tax liability and timely filed a refund claim with the Internal Revenue Service (“IRS”) stating the grounds for the claim. See 28 U.S.C. § 1491(a); see also 26 U.S.C. §§ 6511(a), 7422(a); Shore v. United States, 9 F.3d 1524, 1526 (Fed.Cir.1993) (<HOLDING>). If the claim is denied by the IRS and the
holding that a tax refund claim must be dismissed if the principal tax deficiency has not been paid in full holding that even in a pro se tax suit a timely claim for refund must be filed to invoke the courts jurisdiction holding that full payment of the assessment is also required for tax refund suits brought in the united states court of federal claims holding that a refund may include additional taxes paid after the filing of a refund claim so long as the total does not exceed the portion of tax paid prior to the administrative claim holding refund of discriminatory tax required because predeprivation remedy not clearly available for tax years at issue