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 of proposed deficiency described in subsection (a)(2)(A)(i) allowing the taxpayer an opportunity for administrative review of such issues in the Internal Revenue Service Office of Appeals before a notice of deficiency is issued under this section. Rules similar to the rules of subsection (a)(2)(B) shall apply for purposes of this subsection. . (c) Effective date The amendments made by this section shall apply to notices of deficiency issued after the date of the introduction of this Act. 3. Appeals dispute resolution procedures Subsection (a) of section 7123 of the Internal Revenue Code of 1986 is amended to read as follows: (a) Referral to appeals procedures The Secretary shall prescribe procedures by which any taxpayer may request— (1) early referral of one or more unresolved issues from the examination or collection division to the Internal Revenue Service Office of Appeals, or (2) consideration by such Office of Appeals of issues included in— (A) a letter of proposed deficiency described in section 6212(a)(2)(A), (B) a notice of deficiency pursuant to section 6212, whether or not the taxpayer has filed a petition with the Tax Court pursuant to section 6213(a), or (C) a claim for refund, whether or not the taxpayer has filed suit in a district court or the United States Court of Federal Claims with respect to the issues included in such claim or refund. Such regulations may limit such procedures 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). Such procedures shall not be available in the case of issues designated for litigation in accordance with section 7124, and the