USA Amending taxes beyond 3 years old - 26 USC 6511: Limitations on credit or refund

[INVINC]

My girlfriend discovered that she did not deduct enough of her expenses from a rental for multiple years. Her current accountant filed amendments for three years, but the problem began for years even before these. Her accountant did not think it was possible to make amendments going back further.

In reading 26 USC 6511: Limitations on credit or refund here:

http://uscode.house.gov/view.xhtml?req=(title:26 section:6511

it states:

Limit where claim not filed within 3-year period
If the claim was not filed within such 3-year period, the amount of the credit or refund shall not exceed the portion of the tax paid during the 2 years immediately preceding the filing of the claim.

This is a bit confusing to me. Am I understanding this correctly that she can still have the amendments made for years beyond the last three? If so, how does the "limit" work re amount of the refund? What is needed to get the refund for these items? If not, please advise, including anything she may be able to do re this.

Much thanks...

 

[INVINC]

Any insights on this?