The Statute of Limitations provided in O.C.G.A. § 48-2-49 and O.C.G.A. § 48-7-82 does not apply to an examination of the records of any taxpayer under this law, by the Commissioner or his agent.
Ga. Comp. R. & Regs. R. 560-7-8-.12
O.C.G.A. Secs. 48-2-12, 48-2-49, 48-7-82.