In the case of a taxpayer who fails to file a return, underreports his income by twenty five percent (25%) or more, or fails to notify the director of any change or correction by the Internal Revenue Service, no amended return or verified claim for credit or refund will be allowed after 3 years from the date the original return or the notification of change by the Internal Revenue Service was originally due.
1.26 Ark. Code R. 18-306(i)(2)