JUSTICE THOMAS delivered the opinion of the Court.
Section 6501(a) of the Internal Revenue Code states that, except as otherwise provided, "the amount of any tax imposed by this title shall be assessed within 3 years after the return was filed . . . and no proceeding in court without assessment for the collection of such tax shall be begun after the expiration of such period." 26 U. S. C. § 6501(a). If a tax is properly assessed within three years, however, the...
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