(1) After ninety days from the date of mailing of a copy of the notice of assessment, if no petition for reassessment has been filed;

(2) After ninety days from the date of mailing of notice of the department's action thereon, if no petition for review has been filed;

(3) Within thirty days from the date of mailing of notice of the decision of the Board of Finance and Revenue upon a petition for review or from the expiration of the board's time for acting upon such petition, if no decision has been made; or

(4) Immediately, in all cases of judicial sales, receiverships, assignments or bankruptcies.

In any such proceeding for the collection of the tax imposed by this article,¹ the person against whom the assessment was made shall not be permitted to set up any ground of defense that might have been presented to the department, the Board of Finance and Revenue or the Commonwealth Court if such person had properly pursued his administrative remedies under this article.