Rejecting tax court precedent, the Seventh Circuit ruled Friday that delinquent taxpayers who weren’t properly notified of Internal Revenue Service levies still have to pursue an administrative appeal before they can petition the tax court to invalidate the levy.

Acknowledging the difficulty it presents to taxpayers, the Seventh Circuit nevertheless found tax courts don’t have jurisdiction to rule on petitions to invalidate levies unless the taxpayer went to the IRS Office of Appeals first and received a notice of determination.

The case is Kerry Adolphson v. Commissioner of Internal Revenue, case number 15-2242 in the Seventh Circuit Court of Appeals.