Appeals do not suspend collection of undisputed amounts

—(1) If a request for review of an assessment has been filed or a taxpayer has appealed to the Board against an assessment, the undisputed tax liability remains due and payable, unless the Director General grants an extension of time under section 52. (2) Notwithstanding sub-section (1), the Board or the Supreme Court may rule, upon the Director General’s motion, that all or a portion of the tax is being disputed on a frivolous basis, in which case such amount becomes due and payable.