112 STAT. 760 PUBLIC LAW 105-206—JULY 22, 1998 "(i) any counterclaim in a proceeding under such paragraph; or "(ii) any proceeding relating to a proceeding under such paragraph. "(B) AUTHORITY TO ENJOIN.—Notwithstanding section 7421(a), a levy or collection proceeding prohibited by this subsection may be enjoined (during the period such prohibition is in force) by the court in which the proceeding under paragraph (1) is brought. "(5) SUSPENSION OF STATUTE OF LIMITATIONS ON COLLEC- TION.— The period of limitations under section 6502 shall be suspended for the period during which the Secretary is prohibited under this subsection from making a levy. "(6) PENDENCY OF PROCEEDING. —For purposes of this subsection, a proceeding is pending beginning on the date such proceeding commences and ending on the date that a final order or judgment from which an appeal may be taken is entered in such proceeding.". 26 USC 6331 (b) EFFECTIVE DATE. —The amendment made by this section note. shall apply to unpaid tax attributable to taxable periods beginning after December 31, 1998. SEC. 3434, APPROVAL REQUIRED FOR JEOPARDY AND TERMINATION ASSESSMENTS AND JEOPARDY LEVIES. (a) IN GENERAL. — Paragraph (1) of section 7429(a) (relating to review of jeopardy levy or assessment procedures) is amended to read as follows: "(1) ADMINISTRATIVE REVIEW.— "(A) PRIOR APPROVAL REQUIRED.— No assessment may be made under section 6851(a), 6852(a), 6861(a), or 6862, and no levy may be made under section 6331(a) less than 30 days after notice and demand for payment is made, unless the Chief Counsel for the Internal Revenue Service (or such Counsel's delegate) personally approves (in writing) such assessment or levy. "(B) INFORMATION TO TAXPAYER. —Within 5 days after the day on which such an assessment or levy is made, the Secretary shall provide the taxpayer with a written statement of the information upon which the Secretary relied in making such assessment or levy.". Applicability. (b) EFFECTIVE DATE. —The amendment made by this section 26 USC 7429 shall apply to taxes assessed and levies made after the date of °°*®- the enactment of this Act. SEC. 3435. INCREASE IN AMOUNT OF CERTAIN PROPERTY ON WHICH LIEN NOT VALID. (a) CERTAIN PROPERTY.— (1) IN GENERAL. —Subsection (b) of section 6323 (relating to validity and priority against certain persons) is amended— (A) by striking "$250" in paragraph (4) (relating to personal property purchased in casual sale) and inserting "$1,000"; and (B) by striking "$1,000" in paragraph (7) (relating to residential property subject to a mechanic's lien for certain repairs and improvements) and inserting "$5,000". (2) INFLATION ADJUSTMENT.— Subsection (i) of section 6323 (relating to special rules) is amended by adding at the end the following new paragraph:
�
