- 12 - 1985. We agree with respondent that section 6330(c)(4) bars our consideration of the issue. As a threshold matter, we note that respondent carried out the 1998 levy before section 6330 became effective. See supra note 3. Consequently, petitioner did not have an opportunity for pre-levy administrative or judicial review before respondent collected funds from her retirement account. The record shows, however, that petitioner promptly obtained post-levy administrative review by filing with respondent claims for refund for 1982 and 1985. Respondent considered petitioner’s claims and granted petitioner partial relief by abating some of the earlier assessments recorded for the taxable year 1982 and issuing petitioner a refund for that year. Respondent disallowed a relatively small portion of the remainder of petitioner’s claim for refund for 1982 and her entire claim for refund for 1985.5 Undaunted, petitioner subsequently requested the assistance of the TAS, but to no avail--the TAS concluded that petitioner was not entitled to the refunds she sought. In an attempt to resurrect the issue a third time, petitioner asserts that she is entitled to prepayment credits from the taxable years 1982 and 1985 as a defense to respondent’s 5 Although it is clear that petitioner’s refund claims were disallowed as outlined above, the record does not reflect whether petitioner is eligible to file a refund suit for the taxable years 1982 and 1985 in accordance with secs. 7422(a) and 6532.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: March 27, 2008