Sec. 6. Interest abatement reviews
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Subsection
(h)of section 6404 of the Internal Revenue Code of 1986 is amended— by striking in the heading and inserting Review of denial , and Judicial review by striking if such action is brought and all that follows in paragraph
(1)and inserting if such action is brought— at any time after the earlier of— the date of the mailing of the Secretary's final determination not to abate such interest, or the date which is 180 days after the date of the filing with the Secretary (in such form as the Secretary may prescribe) of a claim for abatement under this section, and not later than the date which is 180 days after the date described in subparagraph (A)(i). . The amendments made by this subsection shall apply to claims for abatement of interest filed with the Secretary after the date of the enactment of this Act. Subsection
(f)of section 7463 of the Internal Revenue Code of 1986 is amended— by striking and at the end of paragraph (1), by striking the period at the end of paragraph
(2)and inserting , and , and by adding at the end the following new paragraph: a petition to the Tax court under section 6404(h) in which the amount of interest abatement sought does not exceed $50,000. . The amendments made by this subsection shall apply to— cases pending as of the day after the date of the enactment of this Act, and cases commenced after such date of enactment.