Page:United States Statutes at Large Volume 114 Part 5.djvu/682

 114 STAT. 2763A-642 PUBLIC LAW 106-554—APPENDIX G "until the close of the 90th day referred to in subparagraph (A)(ii)", and (ii) by inserting "under subparagraph (A)" after "filed with the Tax Court". (D)(i) Subsection (e) of section 6015 is amended by adding at the end the following new paragraph: "(5) WAIVER. —An individual who elects the application of subsection (b) or (c) (and who agrees with the Secretary's determination of relief) may waive in writing at any time the restrictions in paragraph (1)(B) with respect to collection of the outstanding assessment (whether or not a notice of the Secretary's final determination of relief has been mailed).". (ii) Paragraph (2) of section 6015(e) is amended to read as followsf " (2) SUSPENSION OF RUNNING OF PERIOD OF LIMITATIONS.— The running of the period of limitations in section 6502 on the collection of the assessment to which the petition under paragraph (1)(A) relates shall be suspended— "(A) for the period during which the Secretary is prohibited by paragraph (1)(B) from collecting by levy or a proceeding in court and for 60 days thereafter, and "(B) if a waiver under paragraph (5) is made, from the date the claim for relief was filed until 60 days after the waiver is filed with the Secretary.", (b) AMENDMENTS RELATED TO PROCEDURE AND ADMINISTRA- TION.— (1) DISPUTES INVOLVING $50,000 OR LESS.— Section 7463 is amended by adding at the end the following new subsection: "(f) ADDITIONAL CASES IN WHICH PROCEEDINGS MAY BE CON- DUCTED UNDER THIS SECTION.—At the option of the taxpayer concurred in by the Tax Court or a division thereof before the hearing of the case, proceedings may be conducted under this section (in the same manner as a case described in subsection (a)) in the case of— "(1) a petition to the Tax Court under section 6015(e) in which the amount of relief sought does not exceed $50,000, and "(2) an appeal under section 6330(d)(1)(A) to the Tax Court of a determination in which the unpaid tax does not exceed $50,000. ". (2) AUTHORITY TO ENJOIN COLLECTION ACTIONS. — (A) Section 6330(e)(1) is amended by adding at the end the following: "Notwithstanding the provisions of section 7421(a), the beginning of a levy or proceeding during the time the suspension under this paragraph is in force may be enjoined by a proceeding in the proper court, including the Tax Court. The Tax Court shall have no jurisdiction under this paragraph to enjoin any action or proceeding unless a timely appeal has been filed under subsection (d)(1) and then only in respect of the unpaid tax or proposed levy to which the determination being appealed relates.". (B) Section 7421(a) is amended by inserting " 633 0(e)( D," after "6246(b),". (3) CLARIFICATION.—Paragraph (3) of section 633l(k) is amended by striking "(3), (4), and (5)" and inserting "(3) and (4)".

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