26 U.S.C. § 6696 — Rules applicable with respect to sections 6694, 6695, 6695A, and 6695B

The amount of any penalty under section 6694(a), 6695, or 6695A shall be assessed within 3 years (or, in the case of any penalty under section 6695B, 6 years) after the return or claim for refund with respect to which the penalty is assessed was filed, and no proceeding in court without assessment for the collection of such tax shall be begun after the expiration of such period. In the case of any penalty under section 6694(b), the penalty may be assessed, or a proceeding in court for the collection of the penalty may be begun without assessment, at any time.

Except as provided in section 6694(d), any claim for refund of an overpayment of any penalty assessed under section 6694, 6695, or 6695A shall be filed within 3 years (or, in the case of any claim for refund of an overpayment of any penalty assessed under section 6695B, 6 years) from the time the penalty was paid.

The term “return” means any return of any tax imposed by this title, any administrative adjustment request under section 6227, and any partnership^* adjustment tracking report under section 6226(b)(4)(A).

The term “claim for refund” means a claim for refund of, or credit against, any tax imposed by this title.