Tax on certain prohibited allocations of qualified securities

If— For purposes of this section, the term “prohibited allocation” means— The tax imposed by this section shall be paid— in the case of an allocation referred to in paragraph (1) or (2) of subsection (a), by— The statutory period for the assessment of any tax imposed by this section on an allocation described in subsection (a)(2) of qualified employer securities shall not expire before the date which is 3 years from the later of— For purposes of this section— Except as provided in paragraph (2), terms used in this section have the same respective meanings as when used in sections 409 and 4978. The amount involved with respect to any tax imposed by reason of subsection (a)(3) is the amount allocated to the account of any person in violation of section 409(p)(1). The amount involved with respect to any tax imposed by reason of subsection (a)(4) is the value of the shares on which the synthetic equity is based. For purposes of subparagraph (A), the amount involved for the first nonallocation year of any employee stock ownership plan shall be determined by taking into account the total value of all the deemed-owned shares of all disqualified persons with respect to such plan. The statutory period for the assessment of any tax imposed by this section by reason of paragraph (3) or (4) of subsection (a) shall not expire before the date which is 3 years from the later of—