26 U.S.C. § 7485 — Bond to stay assessment and collection

(a) Upon notice of appeal: despite other laws limiting assessment and collection, appealing under section 7483 does not pause the IRS from assessing or collecting the deficiency^* the Tax Court^* found - unless the taxpayer^* files a notice of appeal for that part of it, and either (1) files a bond with the Tax Court, before or when filing the appeal, for up to double the disputed amount, with surety the Tax Court approves, promising to pay the final deficiency plus interest and penalties, or (2) already has a jeopardy bond filed under the income or estate tax laws. If part of the deficiency gets paid later - because restrictions on assessment were waived - the bond must be reduced proportionally if the taxpayer asks.

(b) Bond in case of appeal of certain partnership^*-related decisions: this bond requirement is satisfied for a partnership appealing a decision under section 6234 if, by the time the notice of appeal is filed, a bond the Tax Court approves is filed, promising to pay the final deficiencies tied to the partnership-related items (as section 6241 defines them) that the decision covers, plus interest, penalties, and additions to tax. Unless the parties agree otherwise, the Tax Court sets the bond amount based on its estimate of the total amount owed.

(c) Cross references: (1) for the rule allowing courts to require extra security anyway, see section 7482(c)(3); (2) for depositing U.S. bonds or notes instead of using sureties, see 31 U.S.C. § 9303.