Replaces subsection (d)(1) of 26 U.S.C. 6330 to specify Tax Court petition rights and to expand the Tax Court's jurisdiction to include review of underlying tax liabilities properly disputed at the CDP hearing and equitable tolling of the 30-day deadline; clarifies that these provisions apply whether or not the Secretary abandons the collection action.

Adds new subsection (o) to 26 U.S.C. 6402 prohibiting crediting an overpayment against a properly disputed underlying tax liability during collection action proceedings (when a hearing under section 6320(a)(3)(B) or 6330(a)(3)(B) is properly requested and the liability is properly disputed) for the period during which the period of limitations for filing a claim for credit or refund is suspended by reason of section 6330(e), except with the consent of the taxpayer.

Adds a new paragraph (8) to section 6511(i) providing a cross-reference to section 6330(e) for limitations in the case of collection action proceedings.

Amends 6330(c)(2)(A) by striking the phrase 'unpaid tax or the proposed levy' and inserting 'unpaid tax, collection action, or proposed collection action'.