Sig and Barbara Shore v. United States

WOODS, District Judge.

Sig and Barbara Shore (the taxpayers) brought an action in the United States Court of Federal Claims 1 for a refund of assessed taxes which they had paid. 2 The taxpayers now petition for review of the August 21, 1992 judgment of that court, dismissing their action for lack of subject matter jurisdiction due to their failure to pay the assessed penalties and interest. Because the full payment rule set forth in Flora v. United States, 357 U.S. 63, 78, 78 S.Ct. 1064, 1079, 2 L.Ed.2d 1165 (1958), aff'd on reh’g, 362 U.S. 145, 80 S.Ct. 630, 4 L.Ed.2d 623 (1960), does not…