The tax administrator shall give to the seller a written notice of his or her determination. Except in the case of fraud, intent to evade the provisions of this chapter, or failure to make a return, every notice of a determination shall be mailed within three (3) years after the tenth day of the calendar month following the month for which the amount is proposed to be determined or within three (3) years after the return is filed, whichever period expires later, unless a longer period is agreed upon by the tax administrator and the seller.