Justice BREYER delivered the opinion of the Court, except as to Part IV-C.
Ordinarily, the Government must assess a deficiency against a taxpayer within "3 years after the return was filed." 26 U.S.C. § 6501(a) (2000 ed.). The 3-year period is extended to 6 years, however, when a taxpayer "omits from gross income an amount properly includible therein which is in excess of 25 percent of the amount of gross income stated in the return." § 6501(e)(1...
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