Here is how I read 6511(a):
Claim for refund must be made the latter of:
a.) 3 years from when the return was filed; or
b.) 2 years from when the tax was paid
c.) if no return was filed, 2 years from when the tax was paid
Since this section does not distinguish between timely and untimely returns, if I file a 2010 return in 2016, it seems like c.) does not apply because a return is filed and the 3 year clock starts when I file my return, regardless of how late it is.
Common sense says this won't float, but I don't find anything in other sections of the Code that negate my interpretation.
Am I missing something?