... Flora v. United States, 362 U.S. 145, 157 (1960). Section "1346(a)(1) must be read in conformity with other statutory provisions [26 U.S.C. §§ 7422(a) and 6511(a)] which qualify a taxpayer's right to bring a refund suit." United States v. Dalm, 494 U.S. 596,601-602 (1990). Section 1346(a)(1) provides: "The district courts shall have original jurisdiction, concurrent with the United States Court of Federal Claims, of: "(1) Any civil action against the United States for the recovery of any internal revenue tax alleged to have been erroneously or illegally assessed or collected, or any penalty claimed to have been collected without authority or any sum alleged to have been excessive or in any manner wrongfully collected under the internal revenue laws." 28 U.S.C. § 1346(a)(1) (1988 ed. and Supp V). The jurisdiction conferred by §1346(a)(1) is limited by 26 U.S.C. § 7422(a). Like §1346(a)(1), §7422(a) contains no language limiting a ...

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