7, 2007 e-mail requests for clarification on several issues, on May 9, 2007, the Government filed a Motion for Leave to Submit Calculations, which the court granted. On May 10, 2007, Plaintiffs filed a Motion for Leave to Submit Calculations and the May 9, 2007 Declaration of Hendy J. Lund, which the court granted. On May 10, 2007, the court held an oral argument. III. DISCUSSION. A. Jurisdiction. The Tucker Act authorizes the United States Court of Federal Claims to adjudicate tax refund claims. See 28 U.S.C. § 1491(a). As a prerequisite, however, a taxpayer must pay the full assessed federal tax liability and timely file a refund claim with the IRS stating the grounds for the claim. See 26 U.S.C. §§ 6511(a), 7422(a); see also 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 even in a pro se tax suit a timely claim for refund must be filed to invoke the courts jurisdiction 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 holding that a tax refund claim must be dismissed if the principal tax deficiency has not been paid in full holding that full payment of the assessment is also required for tax refund suits brought in the united states court of federal claims