804
INTERNAL REVENUE CODE OF 1954
(3) N o EETURN.—In the case of failure to file a return, the tax may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, at any time. (4) EXTENSION BY AGREEMENT.—Where, before the expiration of the time prescribed in this section for the assessment of any tax imposed by this title, except the estate tax provided in chapter 11, both the Secretary or his delegate and the taxpayer have consented in writing to its assessment after such time, the tax may be assessed at any time prior to the expiration of the period agreed upon. The period so agreed upon may be extended by subsequent agreements in writing made before the expiration of the period previously agreed upon. (5) T A X RESULTING FROM CHANGES IN CERTAIN INCOME TAX OR ESTATE TAX CREDITS.-—
For special rules applicable in cases where the adjustment of certain taxes allowed as a credit against income taxes or estate taxes results in additional tax, see section 905(c) (relating to the foreign tax credit for income tax purposes) and section 2016 (relating to taxes of foreign countries, States, etc., claimed as credit against estate taxes). (d) K E Q U E S T
FOR PROMPT ASSESSMENT.—Except
as
otherwise
provided in subsection (c), in the case of any tax (other than the tax imposed by chapter 11 of subtitle B, relating to estate taxes) for which return is required in the case of a decedent, or by his estate during the period of administration, or by a corporation, the tax shall be assessed, and any proceeding in court without assessment for the collection of such tax shall be begun, within 18 months after written request therefor (filed after the return is made and filed in such manner and such form as may be prescribed by regulations of the Secretary or his delegate) by the executor, administrator, or other fiduciary representing the estate of such decedent, or by the corporation, b u t not after the expiration of 3 years after the return was filed. This subsection shall not apply in the case of a corporation unless— (1) Such written request notifies the Secretary or his delegate that the corporation contemplates dissolution a t or before the expiration of such 18-month period; and (2) The dissolution is in good faith begun before the expiration of such 18-month period; and (3) The dissolution is completed. (e) OMISSION FROM GROSS INCOME.—Except as otherwise provided
in subsection (c)— (1) INCOME TAXES.—In the case of any tax imposed by subtitle A— (A) GENERAL RULE.—If the taxpayer omits from gross income an amount properly includible therein which is in excess of 25 percent of the amount of gross income stated in the return, the tax may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, a t any time within 6 years after the return was filed. For purposes of this subparagraph— (i) I n the case of a trade or business, the term "gross income" means the total of the amounts received or accrued from the sale of goods or services (if such amounts are required to be shown on the return) prior to diminution by the cost of such sales or services; and §6501 (c)(3)
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