Shore v. United States

OPINION

REGINALD W. GIBSON, Judge:

INTRODUCTION

In this tax refund suit filed on October 26, 1989, plaintiffs, Sig and Barbara Shore, jointly seek a refund of federal income taxes in the amounts of $54,174 and $14,783 for the tax years 1974 and 1975, respectively. In response to this court’s sua sponte order of May 5, 1992, raising jurisdictional issues, the parties have submitted briefs addressing the applicability of the “full payment rule,” as discussed by the Supreme Court in Flora v. United States, 357 U.S. 63, 78 S.Ct. 1079, 2 L.Ed.2d 1165 (1958), aff’d on reh’g, 362 U.S. 145, 80 S.Ct.…