PUBLIC LAW 100-647—NOV. 10, 1988

102 STAT. 3751

Secretary's determination under subparagraph (B) that the
property may be sold. Such review may be commenced upon
motion by either the Secretary or the taxpayer. An order of the
Tax Court disposing of a motion under this paragraph shall be
reviewable in the same manner as a decision of the Tax Court."
(b) effective date.—The amendments made by this section shall 26 USC 6863
take effect on the 90th day after the date of the enactment of this   note.
Act.
SEC. 6246. JURISDICTION TO REDETERMINE INTEREST ON DEFICIENCIES.
(a)	in general.—Section 7481 of the 1986 Code (relating to date
when Tax Court decision becomes final) is amended by adding at the
end thereof the following new subsection:
"(c) jurisdiction over interest determinations.—Notwith-
standing subsection (a), if—
"(1) an assessment has been made by the Secretary under
section 6215 which includes interest as imposed by this title,
"(2) the taxpayer has paid the entire amount of the deficiency
plus interest claimed by the Secretary, and
"(3) within 1 year after the date the decision of the Tax Court
becomes final under subsection (a), the taxpayer files a petition
in the Tax Court for a determination that the amount of
interest claimed by the Secretary exceeds the amount of
interest imposed by this title,
then the Tax Court may reopen the case solely to determine
whether the taxpayer has made an overpayment of such interest
and the amount of any such overpayment. If the Tax Court deter-
mines under this subsection that the taxpayer has made an overpay-
ment of interest, then that determination shall be treated under
section 6512(bXl) as a determination of an overpayment of tax. An
order of the Tax Court redeteraainiiig the interest due, when entered
upon the records of the court, shall be reviewable in the same
manner as a decision of the Tax Court."
(b)	conforming amendments.—
(l)_a Section	of the 1986 Code (relating to effect of
petition to Tax Court) is amended by inserting after "section
6213(a)" the following: "(or 7481(c) with respect to a determina-
tion of statutory interest)".
(2) Subsection (a) of section 7481 of the 1986 Code is amended
by striking out "subsection (b)" and inserting in lieu thereof
"subsections (b) and (c)".
(c)	effective date.—The amendments made by this section shall   26 USC 6512
apply to assessments of deficiencies redetermined by the Tax Court   note.
made after the date of the enactment of this Act.
SEC. 6247.	TO	DECISIONS IN CERTAIN ESTATE TAX
CASES.
(a) in general.—Action 7481 of the 1986 Code (relating to date
when Tax Court decision becomes final),, as amended by section
783(a), is further amended by adding at the end thereof the following
new subsection:
"(d) decisions relating To estate tax extended under sec-
tion 6166.—If with	to a decedent's estate subject to a
decision of the Tax Court—
"(1) the time for payment of an amount of tax imposed by
chapter 11 is	under section 6166,