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CCH (cch.taxgroup.com) reports:

Neither an IRS levy on a taxpayer's cash and other liquid assets nor the placement of these funds into an escrow account pending final resolution of a disputed tax liability constituted the payment of the liability that stopped the accrual of interest. The levy only gave the IRS a security interest in the property. Since it did not transfer ownership to the IRS, it was not a payment of the disputed tax. Likewise, the placement of the property into an escrow account was not a payment of the disputed tax because the terms of the escrow specifically provided that escrowed amounts did not constitute a payment.
Affirming FedCl, 2003-1 USTC ¶50,407.
LaRosa's International Fuel Co., Inc., CA-FC, 2007-2 USTC ¶50,657
Other References:
Code Sec. 6511
CCH Reference - 2007FED ¶39,080.30
Code Sec. 6601
CCH Reference - 2007FED ¶39,415.168
Tax Research Consultant
CCH Reference - TRC PENALTY: 9,056