112 STAT. 732 PUBLIC LAW 105-206-^ULY 22, 1998 Applicability. 26 USC 7422 note. "(2) ESTATES TO WHICH SUBSECTION APPLIES. —This subsection shall apply to any estate if, as of the date the action is filed— "(A) no portion of the installments payable under section 6166 have been accelerated; "(B) all such installments the due date for which is on or before the date the action is filed have been paid; "(C) there is no case pending in the Tax Court with respect to the tax imposed by section 2001 on the estate and, if a notice of deficiency under section 6212 with respect to such tax has been issued, the time for filing a petition with the Tax Court with respect to such notice has expired; and "(D) no proceeding for declaratory judgment under section 7479 is pending. "(3) PROHIBITION ON COLLECTION OF DISALLOWED LIABIL- ITY.—I f the court redetermines under paragraph (1) the estate tax liability of an estate, no part of such liability which is disallowed by a decision of such court which has become final may be collected by the Secretary, and amounts paid in excess of the installments determined by the court as currently due and payable shall be refunded.". (b) EXTENSION OF TIME TO FILE REFUND SUIT.— Section 7479 (relating to declaratory judgments relating to eligibility of estate with respect to installment payments under section 6166) is amended by adding at the end the following new subsection: "(c) EXTENSION OF TIME TO FILE REFUND SUIT.—The 2-year period in section 6532(a)(1) for filing suit for refund after disallowance of a claim shall be suspended during the 90-day period after the mailing of the notice referred to in subsection (b)(3) and, if a pleading has been filed with the Tax Court under this section, until the decision of the Tax Court has become final.". (c) EFFECTIVE DATE. —The amendments made by this section shall apply to any claim for refund filed after the date of the enactment of this Act. SEC. 3105. ADMINISTRATIVE APPEAL OF ADVERSE INTERNAL REVENUE SERVICE DETERMINATION OF TAX-EXEMPT STATUS OF BOND ISSUE. The Internal Revenue Service shall amend its administrative procedures to provide that if, upon examination, the Internal Revenue Service proposes to an issuer that interest on previously issued obligations of such issuer is not excludable from gross income under section 103(a) of the Internal Revenue Code of 1986, the issuer of such obligations shall have an administrative appeal of right to a senior officer of the Internal Revenue Service Office of Appeals. SEC. 3106. CIVIL ACTION FOR RELEASE OF ERRONEOUS UEN. (a) RIGHT OF SUBSTITUTION OF VALUE. — Subsection (b) of section 6325 (relating to release of lien or discharge of property) is amended by adding at the end the following new paragraph: "(4) RIGHT OF SUBSTITUTION OF VALUE. — "(A) IN GENERAL. —At the request of the owner of any property subject to any lien imposed by this chapter, the Secretary shall issue a certificate of discharge of such property if such owner— "(i) deposits with the Secretary an amount of money equal to the value of the interest of the United
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