PUBLIC LAW 100-647—NOV. 10, 1988 102 STAT. 3741

(1) IN GENERAL.—The amendments made by this section
(other than subsection (g)) shall apply to levies issued on or after
July 1,1989.

(2) SUBSECTION (g).—The amendment made by subsection (g)
shall apply to requests made on or after January 1, 1989.

SEC. 6237. REVIEW OF JEOPARDY LEVY AND ASSESSMENT PROCEDURES.

(a) IN GENERAL.—Subsection (a)(l) of section 7429 of the 1986 Code
(relating to review of jeopardy assessment procedures) is amended—

(1) by inserting "or levy is made under section 6331(a) less
than 80 days after notice and demand for payment is made
under section 6331(a)," after "6862,", and

(2) by inserting "or levy" after "such assessment".

(b) ADMINISTRATIVE DETERMINATIONS.—Paragraph (3) of section
7429(a) of the 1986 Code (relating to redetermination by the Sec-
retary) is amended to read as follows:

"(3) REDETERMINATION BY SECRETARY.—After a request for
review is made under paragraph (2), the Secretary shall deter-
mine—

"(A) whether or not—

"(i) the making of the assessment under section 6851,
6861, or 6862, as the case may be, is reasonable under
the circumstances, and

"(ii) the amount so assessed or demanded as a result
of the action taken under section 6851, 6861, or 6862 is
appropriate under the circumstances, or
"(B) whether or not the levy described in subsection (aXl)
is reasonable under the circumstances."

(c) TAX COURT REVIEW JURISDICTION.—Subsection (b) of section
7429 of the 1986 Code is amended to read as follows:

"(b) JUDICIAL REVIEW.—

"(1) PROCEEDINGS PERMITTED.—Within 90 days after the
earlier of—

"(A) the day the Secretary notifies the taxpayer of the
Secretary's determination described in subsection (aX3), or
"(B) the 16th day after the request described in subsection
(aX2) was made,

the taxpayer may bring a civil action against the United States
for a determination under this subsection in the court with
jurisdiction determined under paragraph (2).
"(2) JURISDICTION FOR DETERMINATION.—

"(A) IN GENERAL.—Except as provided in subparagraph
(B), the district courts of the United States shall have
exclusive jurisdiction over any civil action for a determina-
tion under this subsection.

"(B) TAX COURT.—If a petition for a redetermination of a
deficiency under section 6213(a) has been timely filed with
the Tax Court before the malting of an assessment or levy
that is subject to the review procedures of this section, and
1 or more of the taxes and taxable periods before the Tax
Court because of such petition is also included in the writ-
ten statement that is provided to the taxpayer under
subsection (a), then the Tax Court also shall have jurisdic-
tion over any civil action for a determination under this
subsection with respect to all the taxes and taxable periods
included in such written statement.