Flora v. United States

Case Date: 05/04/1960

Flora v. United States, 357 U.S. 63 (1958), aff'd on rehearing, 362 U.S. 145 (1960), was a case in which the United States Supreme Court held that a taxpayer generally must pay the full amount of an income tax deficiency assessed by the Commissioner of Internal Revenue before he may challenge its correctness by a suit in a federal district court for refund under 28 U.S.C. § 1346(a)(1). The Supreme Court agreed with the Commissioner, stating that the "full payment rule" requires that the entire amount of an asserted deficiency be paid before a refund suit may be maintained.