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In light of the foregoing, we hold that respondent issued a
valid notice of deficiency and that such notice served to toll
the running of the period of limitations for assessment and
collection.
2. Effect of Form 4549
Petitioner also contends that the execution of Form 4549
conclusively determined his total tax liability for 1982 and that
respondent is therefore barred from making any subsequent
assessment for that year.
It has long been established that the statutory procedure
provided under section 7121 is the exclusive method by which an
agreement regarding a taxpayer's tax liability may be accorded
finality. See Hudock v. Commissioner, 65 T.C. 351, 362 (1975),
and cases cited therein; see also Person v. Commissioner, T.C.
Memo. 1985-211. (Because Congress has provided a way in which
the Commissioner may be bound, the possibility of being bound by
some other procedure is precluded.) Section 7121 authorizes the
Commissioner to enter into an agreement in writing, referred to
as a "closing agreement", with any person in respect of any tax
for any taxable period. See secs. 7121(a), 7701(a)(11)(B). A
closing agreement becomes final and conclusive when approved by
the Commissioner. Sec. 7121(b).
Section 301.7121-1(d), Proced. & Admin. Regs., provides that
all closing agreements shall be executed on forms prescribed by
the Internal Revenue Service. The Internal Revenue Service has
prescribed Forms 866 and 906 for this purpose. Form 866,
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