816
INTERNAL REVENUE CODE OF 1954
after the date of enactment of this title, and except that such period shall not, with the application of this amendment, expire prior to the date which is 3 years after the date of enactment of this title.) Where a complaint is instituted before a commissioner of the United States within the period above limited, the time shall be extended until the date which is 9 months after the date of the making of the complaint before the commissioner of the United States. For the purpose of determining the periods of limitation on criminal prosecutions, the rules of section 6513 shall be applicable. SEC. 6532. PERIODS OF LIMITATION ON SUITS. (a) S U I T S BY T A X P A Y E R S FOR R E F U N D. — (1) GENERAL RULE.—No suit or proceeding under section 7422
(a) for the recovery of any internal revenue tax, penalty, or other sum, shall be begun before the expiration of 6 months from the date of filing the claim required under such section unless the Secretary or his delegate renders a decision thereon within that time, nor after the expiration of 2 years from the date of mailing by registered maU by the Secretary or his delegate to the taxpayer of a notice of the disallowance of the part of the claim to which the suit or proceeding relates. (2) EXTENSION OF TIME.—The 2-year period prescribed in paragraph (1) shall be extended for such period as may be agreed upon in writing between the taxpayer and the Secretary or his delegate. (3) W A IV E R OF NOTICE OF DISALLOWANCE.—If any person files a written waiver of the requirement that he be mailed a notice of disallowance, the 2-year period prescribed in paragraph (1) shall begin on the date such waiver is filed. (4) RECONSIDERATION AFTER MAILING OF NOTICE.—Any consideration, reconsideration, or action by the Secretary or his delegate with respect to such claim following the mailing of a notice by registered mail of disallowance shall not operate to extend the period within which suit may be begun. (b) SUITS BY UNITED STATES FOR RECOVERY
OF ERRONEOUS
REFUNDS.—Recovery of an erroneous refund by suit under section 7405 shall be allowed only if such suit is begun within 2 years after the making of such refund, except that such suit may be brought a t any time within 5 years from the making of the refund if it appears that any part of the refund was induced by fraud or misrepresentation of a material fact. SEC. 6533. CROSS REFERENCES. (1) For period of limitation in respect of civil actions for fines, penalties, and forfeitures, see section 2462 of Title 28 of the United States Code. (2) For extensions of time by reason of armed service in a combat zone, see section 7508. (3) For suspension of running of statute until 3 years after termination of hostilities, see section 3287 of Title 18.
§6531
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