FAILURE TO AGREE TO EXTENSION NOT TAKEN INTO ACCOUNT.

Sec. 703. FAILURE TO AGREE TO EXTENSION NOT TAKEN INTO ACCOUNT. (a) In general.— Paragraph (1) of section 7430(b) (relating to requirement that administrative remedies be exhausted) is amended by adding at the end the following new sentence: “Any failure to agree to an extension of the time for the assessment of any tax shall not be taken into account for purposes of determining whether the prevailing party meets the requirements of the preceding sentence.”. (b) Effective Date.— The amendment made by this section shall apply in the case of proceedings commenced after the date of the enactment of this Act.