Frank, a calendar year taxpayer, reports $100,000 of gross income and $60,000 of taxable income on his Year 1 return, which he files on March 12 of Year 2. He fails to report on the return a $52,000 long-term capital gain and a $10,000 short-term capital loss. When does the limitations period for the government’s collecting the tax deficiency expire if
a. Frank’s omission results from an oversight?
b. His omission results from a willful attempt to evade the tax?