Whether the IRC section providing for the suspension of levy actions and the running of any period of limitations applies to petitions for a writ of certiorari?

QUESTION PRESENTED Whether the Internal Revenue Code (“IRC”) section providing for the suspension of levy actions and the running of any period of limitations “for the period during which a [collection due process] hearing, and appeals therein, are pending,” 26 U.S.C. §6330(e)(1), was intended by Congress to apply to petitions for a writ of certiorari? vee eet testy gs aM, 1: : ii