26 U.S.C. § 6215: Assessment of deficiency found by Tax Court

If the taxpayer files a petition with the Tax Court, the entire amount redetermined as the deficiency by the decision of the Tax Court which has become final shall be assessed and shall be paid upon notice and demand from the Secretary. No part of the amount determined as a deficiency by the Secretary but disallowed as such by the decision of the Tax Court which has become final shall be assessed or be collected by levy or by proceeding in court with or without assessment. For assessment or collection of the amount of the deficiency determined by the Tax Court pending appellate court review, see section 7485. For dismissal of petition by Tax Court as affirmation of deficiency as determined by the Secretary, see section 7459(d). For decision of Tax Court that tax is barred by limitation as its decision that there is no deficiency, see section 7459(e). For assessment of damages awarded by Tax Court for instituting proceedings merely for delay, see section 6673. For rules applicable to Tax Court proceedings, see generally subchapter C of chapter 76. For extension of time for paying amount determined as deficiency, see section 6161(b).