(a) Except as provided for in Code Section 48-2-51, involving jeopardy assessments, the filing of a petition with the court shall operate as a stay of any enforcement or collection action by the state revenue commissioner with respect to any tax, penalty, interest, or collection costs that are disputed in the petition until the court decision is finalized, including appeals to any appellate court.

(b) Upon petition by the state revenue commissioner, and for good cause shown, the court judge may lift the stay provided for in subsection (a) of this Code section.