NMSA 1978, § 7-1-22 — Exhaustion of administrative remedies

No court of this state has jurisdiction to entertain any proceeding by a taxpayer in
which the taxpayer calls into question the taxpayer's liability for any tax or the
application to the taxpayer of any provision of the Tax Administration Act, except as a
consequence of the appeal by the taxpayer to the court of appeals from the order of a
hearing officer, or except as a consequence of a claim for refund as specified in Section
7-1-26 NMSA 1978.