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 taxpayer’s right to administrative review in the Internal Revenue Service Office of Appeals as provided in section 6212(a)(2) shall not otherwise be denied. . 4. Restriction on Secretarial authority to designate cases for litigation (a) In general Chapter 74 of the Internal Revenue Code of 1986 is amended by redesignating section 7124 as section 7125 and by inserting after section 7123 the following new section: 7124. Restriction on Secretarial authority to designate cases for litigation (a) In general The Secretary may designate issues arising from the examination or collection division for litigation, and not permit the taxpayer to request consideration of such issues by the Internal Revenue Service Office of Appeals under section 7123(a), only to the extent such issues relate to listed transactions (as defined in section 6707A(c)(2)). (b) Settlement In offering terms under a settlement agreement for purposes of the resolution of any issues arising from the examination or collection division, the Secretary may offer terms that preclude the taxpayer from requesting consideration of such issues by the Office of Appeals under section 7123(a) only to the extent such issues relate to listed transactions (as defined in section 6707A(c)(2)). . (b) Clerical amendment The table of sections for chapter 74 of the Internal Revenue Code of 1986 is amended by striking the item relating to section 7124 and inserting the following new items: Sec. 7124. Restriction on Secretarial authority to designate cases for litigation. Sec. 7125. Cross references. . (c) Effective date The amendments made by this section shall apply to the designation of issues for litigation, and offers of settlement terms, after the date of the introduction of this Act. 5. Modification of authority to