Except for adjustments required to be reported for federal purposes under section 6225(a)(2) of the Internal Revenue Code, a taxpayer shall file a claim for refund or credit of tax arising from adjustments made by the Internal Revenue Service on or before the later of:
(1) The expiration of the last date for filing a claim for refund pursuant to ORS 314.415; or
(2) Two years following the date of the federal notice of final partnership adjustment.