In 2008, Gupta sold some shares of Wingo, a private U.S. corporation, for $40 million. On his Form 1040 Schedule D for 2008, Gupta showed the basis of the stock as $11 million, thereby reporting a $29 million capital gain. Gupta filed his return on October 1, 2009, after properly receiving an extension of the filing due date. Other income and deductions on the 2008 return netted to zero. On March 1, 2013, while auditing the tax return of one of the purchasers of Gupta’s Wingo shares, the IRS found that the basis for the shares actually was $3 million. Thus, Gupta’s capital gain should have been $37 million and not $29 million. After auditing Gupta’s 2008 return, the IRS maintains that it can collect the underpaid taxes, plus interest and penalties, because the six-year statute of limitations applies (i.e., Gupta’s return showed a substantial understatement of gross income). Gupta has asked you for tax advice on this matter. Did the statute of limitations expire on October 1, 2012, so that the IRS no longer can pursue the matter? Explain.