On April 15, 2017, Brian filed a fraudulent return for his 2016 tax year. In May 2019, he filed an amended return that was accurate, eliminating all the fraudulent items on the original filed return. The IRS issued a Notice of Deficiency (90-day letter) in August 2020. Was the notice issued in violate of the statute of limitations on assessment? Why or why not? (Please cite to the IRC and refer to the specific IRS form that should be used for a particular purpose. You will also need to cite to Circular 230 where appropriate)