DECISION AND ORDER INTRODUCTION Plaintiffs CRA Holdings U.S., Inc. and Subsidiaries (“Plaintiffs”) commenced the instant action on March 19, 2015, seeking to recover refunds of taxes paid for the 2002 and 2003 tax years. (Dkt. 1). The operative pleading is the First Amended Complaint filed on March 10, 2017. (Dkt. 51). Currently pending before the Court are the following: (1) Plaintiffs’ objections to United States Magistrate Judge Leslie G. Foschio’s Decision and Order with respect to defendant the United States of America’s (“Defendant”) motion to compel (Dkt. 122); (2) Plaintiffs’ motion for voluntary partial dismissal (Dkt. 131); (3) Plaintiffs’ motion for leave to file a second amended complaint (Dkt. 135); (4) Plaintiffs’ motion for leave to file a motion for summary judgment (Dkt. 136); and (5) Defendant’s motion to dismiss for lack of jurisdiction (Dkt. 140). For the reasons that follow, the Court denies Plaintiffs’ motion for leave to file a second amended complaint, grants in part and denies in part Plaintiffs’ motion for voluntary partial dismissal, grants Defendant’s motion to dismiss for lack of jurisdiction, and denies Plaintiffs’ objections to Judge Foschio’s Decision and Order and Plaintiffs’ motion for leave to file a motion for summary judgment as moot. BACKGROUND In their original Complaint, filed on March 19, 2015, Plaintiffs sought a refund of $419,924.00 for the tax year ending September 30, 2002, and a refund of $1,029,402.00 for the tax year ending September 30, 2003, plus interest. (Dkt. 1 at 15). Plaintiffs alleged that the Internal Revenue Service (“IRS”) had improperly rejected their claims for research and development tax credits. (Id. at
10-12). On March 10, 2017, Plaintiffs filed their First Amended Complaint. (Dkt. 51). The First Amended Complaint seeks a refund of $245,077.00 for the tax year ending September 30, 2002, and a refund of $413,066.00 for the tax year ending September 30, 2003, again on the basis that the IRS improperly disallowed Plaintiffs’ claimed research and development tax credits. (Id. at
