Task: Wrong Candidate Generation
Input (English): 2008, as evidenced by Exhibit B to Plaintiffs’ April 3, 2009 Complaint, i.e., a “Certified Promissory Money Note[,]” that states it is a “U.C.C. negotiable instrument redeemable at full face value when presented to [Plaintiffs’ address].” Pl. Ex. B. Plaintiffs later corrected the Promissory Note and proffered it in Plaintiffs’ July 10, 2009 Addendum. Pl. Add. Ex. A. This Promissory Note, however, is not a payment of the taxes due, because it is not a “means of cash or cash equivalents” as required by Section 6311 of the Internal Revenue Code. 26 U.S.C. § 6311; see also 26 C.F.R. § 301.6311-1. Therefore, since Plaintiffs have not paid the taxes at issue, the court does not have jurisdiction over Plaintiffs’ tax refund claim. Shore v. United States, 9 F.3d 1524, 1526 (Fed.Cir.1993) (<HOLDING>). c.The Court Does Not Have Jurisdiction Over 
 Holding statements: (A) holding that in statute authorizing suits against united states limits time period in which such suits may be brought united states retains its sovereign immunity as to any suits brought outside of that time period therefore court does not have subject matter jurisdiction over suit against united states that is barred by statute of limitations (B) holding that a tax refund claim must be dismissed if the principal tax deficiency has not been paid in full (C) holding that the full payment rule is applicable to refund suits in the court of federal claims (D) holding that interest received by a foreign corporation on a tax refund from the united states was interest on an interestbearing obligation of a resident of the united states within income tax statute (E) holding that full payment of the assessment is also required for tax refund suits brought in the united states court of federal claims
Output (English): holding that the full payment rule is applicable to refund suits in the court of federal claims