exaction claim and invokes Tucker Act jurisdiction by alleging that taxes have been improperly collected or withheld by the Government for which the remedy is a refund. See, e.g., City of Alexandria v. United States, 737 F.2d 1022, 1028 (Fed.Cir.1984); see also 28 U.S.C. § 1491(a); New York Life Ins. Co. v. United States, 118 F.3d 1553, 1558 (Fed.Cir.1997) (reaffirming the jurisdiction of the United States Court of Federal Claims over a suit concerning a federal tax refund). To invoke Tucker Act jurisdiction over a tax refund claim, however, a plaintiff must meet three jurisdictional prerequisites. First, a plaintiff must make full payment of the tax, penalties, and interest at issue under the so called “full payment rule.” See Shore v. United States, 9 F.3d 1524, 1527 (Fed.Cir.1993) (<HOLDING>); see also Flora v. United States, 362 U.S.
holding that full payment of the assessment is also required for tax refund suits brought in the united states court of federal claims holding rule applicable to witness holding that the trial court lacked authority to order a refund where the defendants case did not meet the specific statutory requirements authorizing a refund holding that the full payment rule is applicable to refund suits in the court of federal claims holding that the full payment rule literally requires full not partial payment and rejecting the argument that a partpayment remedy is necessary when a taxpayer is too poor to pay the full amount of the tax