payer has forfeited or otherwise lost the right to 
pursue such dispute.’’. 
(c) CROSS REFERENCE.—Section 6511(i) of such 
Code is amended by adding at the end the following new 
paragraph: 
‘‘(8) For limitations in case of collection action 
proceedings, see section 6330(e).’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to the running of any period of 
limitations if such period (determined without regard to 
the amendments made by this section) ends on or after 
the date of the enactment of this Act. 
SEC. 3. PROHIBITION ON CREDITING OF OVERPAYMENTS 
AGAINST DISPUTED TAX LIABILITY DURING 
COLLECTION ACTION PROCEEDINGS. 
(a) IN GENERAL.—Section 6402 of the Internal Rev-
enue Code of 1986 is amended by adding at the end the 
following new subsection: 
‘‘(o) PROHIBITION
ON CREDITING
OF OVERPAY-
MENTS AGAINST DISPUTED TAX LIABILITY DURING COL-
LECTION ACTION PROCEEDINGS.—If a hearing is properly 
requested under section 6320(a)(3)(B) or 6330(a)(3)(B), 
and an underlying tax liability referred to in section 
6330(c)(2)(B) is properly disputed at such hearing, such 
tax liability shall not, except with the consent of the tax-
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payer, be taken into account under subsection (a) for the 
period during which the period of limitations for filing a 
claim for credit or refund relating to such tax liability is 
suspended by reason of section 6330(e).’’. 
(b) CLARIFICATION OF APPLICATION OF CERTAIN 
LEVY HEARING RULES
TO LIEN HEARINGS.—Section 
6330(c)(2)(A) of such Code is amended by striking ‘‘un-
paid tax or the proposed levy’’ and inserting ‘‘unpaid tax, 
collection action, or proposed collection action’’. 
(c) EFFECTIVE DATES.— 
(1) IN
GENERAL.—The amendment made by 
subsection (a) shall apply with respect to any period 
described in section 6402(o) of the Internal Revenue 
Code of 1986 (as added by this section) if any por-
tion of such period is after the date of the enact-
ment of this Act. 
(2) CLARIFICATION OF APPLICATION OF CER-
TAIN LEVY HEARING RULES TO LIEN HEARINGS.— 
The amendment made by subsection (b) shall take 
effect on the date of the enactment of this Act. 
SEC. 4. EXPANSION OF JURISDICTION OF TAX COURT. 
(a) IN GENERAL.—Section 6330(d)(1) of the Inter-
nal Revenue Code of 1986 is amended to read as follows: 
‘‘(1) PETITION FOR REVIEW BY TAX COURT.— 
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‘‘(A) IN GENERAL.—In the case of a deter-
mination under this section, the person may, 
within 30 days of such determination, petition 
the Tax Court for review of— 
‘‘(i) such determination, and 
‘‘(ii) any underlying tax liability re-
ferred to in subsection (c)(2)(B) which is 
properly disputed at the hearing in which 
such determination is made. 
‘‘(B) JURISDICTION
OF
TAX
COURT.— 
Upon the filing of a petition, the Tax Court 
shall have jurisdiction with respect to— 
‘‘(i) the determination referred to in 
subparagraph (A)(i), 
‘‘(ii) any underlying tax liability re-
ferred to in subparagraph (A)(ii), and 
‘‘(iii) any equitable tolling of the 30- 
day deadline referred to in subparagraph 
(A). 
‘‘(C) RETENTION
OF
JURISDICTION.— 
Upon a determination being made under this 
section, subparagraphs (A) and (B) shall apply 
whether or not the Secretary abandons the col-
lection action or proposed collection action at 
issue in such determination.’’. 
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(b) EFFECTIVE DATE.—The amendment made by 
this subsection shall apply with respect to petitions filed 
after the date of the enactment of this Act. 
Æ 
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