①An appeal against a disposition under a law concerning national taxes does not preclude the effect of the disposition that is its subject, the execution of the disposition, or the continuation of procedures; provided, however, that property attached for the collection of the national tax (including the specified real property under participatory attachment prescribed in Article 89-2, paragraph (4) (Conversion into Cash by the District Director Who Made a Participatory Attachment) of the National Tax Collection Act) may not be converted into cash through a delinquent tax collection procedure (including a disposition conducted in accordance with the rules for that procedure; the same applies hereinafter in this Article) until a determination or decision on the appeal is made, except where the value of the property is likely to decrease significantly or where the appellant (or, if the appellant is not the addressee of the disposition, the appellant and the addressee of the disposition) has requested otherwise.

②The reinvestigation authority or the Commissioner of the National Tax Agency may, if they find it necessary, upon the petition of the requester for reinvestigation or of a person who has made a request for review under the provisions of Article 75, paragraph (1), item (ii) or paragraph (2) (limited to the part pertaining to item (ii)) (Appeals against Dispositions concerning National Taxes) (referred to as a "requester for reinvestigation, etc." in the following paragraph), or on their own authority, grant a grace period for the collection of the whole or part of the national tax connected with the disposition that is the subject of the appeal, or suspend the continuation of the delinquent tax collection procedure, or order these measures.

③If a requester for reinvestigation, etc. has provided security and requested that, with regard to the national tax connected with the disposition that is the subject of the appeal, no attachment be made through a delinquent tax collection procedure or an attachment already made through a delinquent tax collection procedure be released, the reinvestigation authority or the Commissioner of the National Tax Agency may, if they find it reasonable, refrain from making that attachment or release that attachment, or order these measures.

④The President of the National Tax Tribunal may, if the President of the National Tax Tribunal finds it necessary, upon the petition of the requester for review or on the President's own authority, after hearing the opinion of the regional commissioner, district director, or director-general of customs who has the authority to collect the national tax connected with the disposition that is the subject of the request for review pursuant to the provisions of Article 43 (Competent Collection Agency for National Taxes) and Article 44 (Special Provisions on the Competent Collection Agency Where Reorganization Proceedings, etc. Have Commenced) (hereinafter referred to as the "competent collection agency" in this Article), request the competent collection agency to grant a grace period for the collection of the whole or part of that national tax or to suspend the continuation of the delinquent tax collection procedure.

⑤If the requester for review has provided security to the competent collection agency and requested that, with regard to the national tax connected with the disposition that is the subject of the request for review, no attachment be made through a delinquent tax collection procedure or an attachment already made through a delinquent tax collection procedure be released, the President of the National Tax Tribunal may, if the President of the National Tax Tribunal finds it reasonable, request the competent collection agency not to make that attachment or to release that attachment.

⑥When the competent collection agency has been requested by the President of the National Tax Tribunal, pursuant to the provisions of paragraph (4), to grant a collection grace period or to suspend the continuation of the delinquent tax collection procedure, or, pursuant to the provisions of the preceding paragraph, not to make an attachment or to release the attachment, the competent collection agency must grant a grace period for the collection of the whole or part of the national tax connected with the disposition that is the subject of the request for review, or suspend the continuation of the delinquent tax collection procedure, or refrain from making that attachment or release that attachment.

⑦The provisions of Article 49, paragraph (1), items (i) and (iii), paragraph (2), and paragraph (3) (Revocation of Tax Payment Grace Period) apply mutatis mutandis to the revocation of a disposition under the provisions of paragraph (2), paragraph (3), or the preceding paragraph. In this case, when the provisions of paragraph (1) of that Article are applied mutatis mutandis to the revocation of a disposition under the provisions of the preceding paragraph, the phrase "the district director, etc." in that paragraph is deemed to be replaced with "the competent collection agency, with the consent of the President of the National Tax Tribunal,".

⑧The review officer (meaning a review officer prescribed in Article 11, paragraph (2) (Representatives) of the Administrative Complaint Review Act; the same applies in Article 108, paragraph (5) (Representatives)) for a request for review under the provisions of Article 75, paragraph (1), item (ii) or paragraph (2) (limited to the part pertaining to item (ii)) may, if the review officer finds it necessary, submit to the Commissioner of the National Tax Agency a written opinion stating that the Commissioner should order the competent collection agency to grant a collection grace period or to suspend the continuation of the delinquent tax collection procedure under the provisions of paragraph (2), or to refrain from making an attachment or to release the attachment under the provisions of paragraph (3).