Marion Warren - Page 8

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          (an offset under section 6402 does not constitute a levy action).           
          If petitioner thinks that he has overpaid his liabilities, as he            
          has alleged in the petition, then it is possible that he may be             
          able to file a claim for refund with the Internal Revenue Service           
          and, if the claim is denied, sue for a refund in the Federal                
          District Court or the Court of Federal Claims.  See McCormick v.            
          Commissioner, 55 T.C. 138, 142 (1970).                                      
               Reviewed and adopted as the report of the Small Tax Case               
               To reflect the foregoing,                                              

                                             An order of dismissal for                
                                        for lack of jurisdiction will                 
                                        be entered.                                   

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