(C) Cases designated for litigation Subparagraph (A) shall not apply in the case of issues designated for litigation in accordance with section 7124. . (b) Opportunity for appeal if fewer than 60 days remain on statute of limitations Section 6212 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 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 enactment of this Act. 604. Limitation on designation of cases as not eligible for referral to Independent Office of Appeals (a) In general If any taxpayer which is in receipt of notice of deficiency authorized under section 6212 of the Internal Revenue Code of 1986 requests referral to the Internal Revenue Service Office of Appeals and such request is denied, the Commissioner of Internal Revenue shall provide such taxpayer a written notice which— (1) provides a detailed description of the facts involved, the basis for the decision to deny the request, and a detailed explanation of how the basis of such decision applies to such facts, and (2) describes the procedures proscribed under subsection (c) for protesting the decision to deny the request. (b) Report to Congress The Commissioner of Internal Revenue shall submit a written report to Congress on an annual basis which includes the number of requests described in