Choice "c" is correct. Generally, the statute of limitations on assessments
is three years from the later of the due date of the return or the date the
return was filed (including amended returns). The IRS has up to six years to
assess additional tax if the misstatement is an understatement of 25% or more of
gross income. In this case, the misstatement is $500 on $20,000 of gross income,
or 2.5%. Therefore, the statute of limitations for Martinsen is the general
rule. In this case, the due date of the return was April 15, Year 2. Martinson
filed on March 31, Year 2. Under the general rule, the IRS has until three years
from April 15, Year 2 (or, April 15, Year 5) to assess additional tax.
Choice "a" is incorrect. In this case, the statute of limitations on
assessments is three years from the later of the due date of the return
or the date the return was filed (including amended returns). March 31 is the
earlier of the two dates.