(A) General rule Where, notwithstanding the provisions of section
6213 (a), an assessment has been made under section
6851,
6852, or
6861, the property seized for the collection of the tax shall not be sold
(i) before the expiration of the periods described in subsection (c)(1)(A) and (B),
(ii) before the issuance of the notice of deficiency described in section
6851 (b) or
6861 (b), and the expiration of the period provided in section
6213 (a) for filing a petition with the Tax Court, and
(iii) if a petition is filed with the Tax Court (whether before or after the making of such assessment), before the expiration of the period during which the assessment of the deficiency would be prohibited if neither sections
6851 (a),
6852 (a), nor 6861(a) were applicable.
Clauses (ii) and (iii) shall not apply in the case of a termination assessment under section 6851 if the taxpayer does not file a return for the taxable year by the due date (determined with regard to any extensions).
(B) Exceptions Such property may be sold if
(i) the taxpayer consents to the sale,
(ii) the Secretary determines that the expenses of conservation and maintenance will greatly reduce the net proceeds, or
(iii) the property is of the type described in section
6336.