context: Third, the taxpayer must pay the IRS the entire tax liability alleged to be due, plus any penalties and interest.
citation_a.signal: see
citation_a.parenthetical: a taxpayer must pay the full amount of income tax deficiency assessed before challenging its correctness in a refund forum
citation_a.sentence: See Flora v. United States, 362 U.S. 145, 154, 80 S.Ct. 630, 4 L.Ed.2d 623 (1960) (a taxpayer must pay the full amount of income tax deficiency assessed before challenging its correctness in a refund forum); see also Shore v. United States, 9 F.3d 1524, 1526 (Fed.Cir.1993) (“The full payment requirement of [26 U.S.C. § ] 1346(a)(1) and Flora applies equally to tax refund suits brought in the Court of Federal Claims[.]”).
citation_b.signal: see also
citation_b.identifier: 9 F.3d 1524, 1526
citation_b.parenthetical: "The full payment requirement of [26 U.S.C. SS ] 1346(a
citation_b.sentence: See Flora v. United States, 362 U.S. 145, 154, 80 S.Ct. 630, 4 L.Ed.2d 623 (1960) (a taxpayer must pay the full amount of income tax deficiency assessed before challenging its correctness in a refund forum); see also Shore v. United States, 9 F.3d 1524, 1526 (Fed.Cir.1993) (“The full payment requirement of [26 U.S.C. § ] 1346(a)(1) and Flora applies equally to tax refund suits brought in the Court of Federal Claims[.]”).