; and (3) by adding at the end the following new paragraph: (2) Opportunity for administrative review in the Office of Appeals (A) In general The requirements of this paragraph are met with respect to a deficiency if, prior to the issuance of the notice of deficiency under paragraph (1)— (i) the taxpayer has been issued a letter of proposed deficiency that explains the basis for the determination of deficiency and allows the taxpayer an opportunity for administrative review in the Internal Revenue Service Office of Appeals, and (ii) either— (I) the time provided in such letter for requesting administrative review in the Internal Revenue Service Office of Appeals has expired and the taxpayer has not made such request, or (II) such Office of Appeals officially concluded the administrative review process with respect to such deficiency. (B) Frivolous tax positions The Secretary is authorized to issue regulations limiting the application of subparagraph (A) in cases involving solely the failure or refusal to comply with the tax laws because of moral, religious, political, constitutional, conscientious, or similar grounds, or for other positions listed as frivolous under section 6702(c). (C) Cases designated for litigation Subparagraph (A) shall not apply in the case of issues designated for litigation in accordance with section 7124, and the taxpayer’s right to administrative review in the Internal Revenue Service Office of Appeals as provided in this paragraph shall not otherwise be denied. . (b) Opportunity for appeal if fewer than 60 days remain on statute of limitations Section 6212 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subsection: (e) Opportunity for appeal if fewer than 60 days remain on statute of limitations In the case of any issues relating to a potential deficiency with respect to which 60 days or fewer remain in the period applicable under section 6501, if the taxpayer agrees to the extension of such period by 12 months, the Secretary shall issue a letter