the statutory period for the assessment of any deficiency attributable to any part of such amount shall not expire before the expiration of 3 years from the date the Secretary is notified by the taxpayer (in such manner as the Secretary may prescribe) of—
(A)#
the amount of the expenditure referred to in subparagraph (A) of subsection (c)(2),
(B)#
the taxpayer’s intention not to make the expenditures referred to in such subparagraph, or
(C)#
a failure to make such expenditure within the period described in subparagraph (B) of subsection (c)(2), and