rule Rules similar to the rules of section 448(c)(2) of the Internal Revenue Code of 1986 shall apply for purposes of paragraph (1)(B). (d) Effective date This section shall apply to conferences occurring after the date which is 1 year after the date of the enactment of this Act. 603. Ensuring taxpayer right to appeal (a) In general Subsection (a) of section 6212 is amended— (1) by striking In general .—If the Secretary and inserting In general .— (1) Authorization If— (A) the Secretary , (2) by striking 44, he is authorized and inserting 44, and (B) the requirements of paragraph (2) have been met with respect to such deficiency, the Secretary is authorized , 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 contacting the Office of Appeals has expired and the taxpayer has not so contacted such Office, or (II) the Office of Appeals has issued a decision 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. . (b) Opportunity for appeal if fewer than 60 days remain on statute of limitations Section 6212 is