Problem: Great Ideas Company deducted the cost of certain new assets acquired in December, 2018 on its 2018 corporate income tax return which was filed on time. Upon examination of that return, the IRS properly took the position that the deduction should have been taken in 2019, when the assets were actually placed in service. Waivers of the statute of limitations for the 2018 were granted through December, 2023. The issue related to the 2018 return was one of several issues taken through appeals, and Great Ideas conceded the fact that the deduction should be taken in the 2019 return. The appeals sessions concluded in November, 2023, and the final Notice of Deficiency for 2018 was issued December 1, 2023. Great Ideas amended its 2019 tax return to claim the deduction and to seek a refund for that year. The IRS denied the refund claim because the statute of limitations for that year closed on March 15, 2023 and no extensions were signed. Does Great Ideas have any avenue to follow in order to claim the refund? Explain.