Tax. Where one section of a statute grants an extended period of time to do X, and Y is an alternative to X, a reference elsewhere in the law saying that X and Y are governed by the initial provision can simply mean that they are separately governed by it.
(Probably.)
http://www.ca2.uscourts.gov/decisions/isysquery/cb713570-cf6f-478b-a928-4f292687255f/1/doc/17-3733_opn.pdf#xml=http://www.ca2.uscourts.gov/decisions/isysquery/cb713570-cf6f-478b-a928-4f292687255f/1/hilite/