Statute of limitations
If the taxpayer for any taxable year treats an amount as a contribution to the capital of the taxpayer described in subsection (c)(1)(A)(i), then—
(1)#
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
(1)(A)#
the amount of the expenditure referred to in subparagraph (A) of subsection (c)(2),
(1)(B)#
the taxpayer’s intention not to make the expenditures referred to in such subparagraph, or
(1)(C)#
a failure to make such expenditure within the period described in subparagraph (B) of subsection (c)(2), and
(2)#
such deficiency may be assessed before the expiration of such 3-year period notwithstanding the provisions of any other law or rule of law which would otherwise prevent such assessment.