Pub. L. 85-866, tit. I, sec. 100
REASONABLE CAUSE FOR FAILURE TO FILE RETURN.
SEC. 100. REASONABLE CAUSE FOR FAILURE TO FILE RETURN. The second sentence of section 106 of the Internal Revenue Code of 1939 (relating to reasonable cause for failure to file a return in cases involving certain claims against the United States) shall apply with respect to taxable years ending after December 31, 1942, in any case in which an amount is received in any taxable year ending after such date by a taxpayer in settlement or a claim arising under the same contract as a claim the settlement of which resulted in the receipt in a subsequent taxable year of an amount to which section 106 (b) of such Code applies. If refund or credit of any overpayment resulting from the application of the preceding sentence is prevented on the date of enactment of this Act, or at any time within one year after such date, by the operation of any law or rule of law (other than section 3760 of the Internal Revenue Code of 1939 or section 7121 of the Internal Revenue Code of 1954, relating to closing agreements, and other than section 3761 of the Internal Revenue Code of 1939 or 72 Stat. 1674 section 7122 of the Internal Revenue Code of 1954, relating to compromises), refund or credit of such overpayment may, nevertheless, be made or allowed if claim therefor is filed within one year after the date of enactment of this Act.