An enrolled agent's (EA's) client is an individual taxpayer who is requesting assistance with a proposed penalty. All of the following are methods of contesting the penalty, EXCEPT:
(A) Prior to a penalty's assessment, the EA can request a review of the penalty
(B) Prior to a penalty's assessment, the EA can request binding arbitration to reconsider the penalty
(C) After the penalty has been assessed, the EA can submit a written request for penalty abatement
(D) After the penalty has been assessed and paid, the EA can file a claim for refund with the IRS
