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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.
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