to cancel assessed amounts that have been “illegally determined ... by the [Bjoard.” § 6981. Taxpayers can assert in their claim for a refund that the Board illegally determined the assessed amount by denying taxpayers the right to present material evidence. Should the Board reject taxpayers’ claim for a refund, taxpayers can seek state court review of the Board’s rejection. See § 6933; see also § 6932 (stating that a claim for a refund before the Board is a prerequisite to filing any state court action for the “recovery of any amount alleged to have been erroneously or illegally determined or collected”). The issues raised and the evidence presented in the administrative claim for a refund, not the petition for redetermin ion, 250 Cal.Rptr. 891, 906, 204 Cal.App.3d 1269, 1291 (1988) (<HOLDING>); Duffy v. State Bd. of Equalization, 199
holding that a constitutional question must be raised at the first available opportunity holding that because the taxpayer raised only the first amendment violation in the claim for a refund the other constitutional grounds for a refund could not be litigated in the state refund action holding that a claim not raised before the trial court will not be considered for the first time on appeal holding that an issue not raised in the trial court cannot be raised for the first time on appeal holding that because a claim was never raised in the district court this court would not consider it for the first time on appeal