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for 1987 through 1994 were improperly intercepted, those refunds
are now available to satisfy his liabilities for the 3 years in
issue.
Section 6402(c) provides in part as follows:
SEC. 6402(c). Offset Of Past-Due Support Against
Overpayments.–-The amount of any overpayment to be
refunded to the person making the overpayment shall be
reduced by the amount of any past-due support * * *
owed by that person of which the Secretary has been
notified by a State * * * . The Secretary shall remit
the amount by which the overpayment is so reduced to
the State collecting such support * * * .
To the extent that petitioner may be seeking to invoke the
overpayment jurisdiction of this Court, see sec. 6512(b), it is
clear that we have no jurisdiction under that section to restrain
or review any credit or reduction made by the Secretary under
section 6402. See sec. 6512(b)(4); see also sec. 6402(e), which
bars any court of the United States, including this Court, from
hearing any action that is commenced to restrain or review a
reduction authorized by section 6402(c);7 Columbus v.
Commissioner, T.C. Memo. 1998-60, affd. without published opinion
162 F.3d 1172 (10th Cir. 1998).
To the extent that petitioner may be seeking to minimize his
liabilities for the years in issue, it is equally clear that we
7 Sec. 6402(e) was redesignated sec. 6402(f) by the
Internal Revenue Service Restructuring and Reform Act of 1998
(RRA 1998), Pub. L. 105-206, sec. 3711(a), 112 Stat. 779. Sec.
6402(e), prior to redesignation, applies to refunds payable under
sec. 6402 on or before Dec. 31, 1999. See RRA 1998 sec. 3711(d),
112 Stat. 781.
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