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against him. He claims that respondent was required to assess
any tax within 1 year from the time Asher signed the closing
agreement on July 9, 1997. Ordinarily, we would not address a
new issue raised on brief. However, we will briefly address it
here because petitioner is a pro se taxpayer and because there is
no merit to the position.
Section 6229(f)(1) provides that, with respect to items
becoming nonpartnership items, “the period for assessing any tax
imposed by subtitle A which is attributable to such items (or any
items affected by such items) shall not expire before the date
which is 1 year after the date on which the items become
nonpartnership items”. The partnership items of a partner become
nonpartnership items when “the Secretary * * * enters into a
settlement agreement with the partner with respect to such
items”. Sec. 6231(b)(1)(C). A settlement agreement is not
entered into until both the partner and the Secretary have signed
it. Therefore, the period of limitations began to run on the
date respondent countersigned Asher’s closing agreement, December
10, 1998, and the assessment, which was made on November 1, 1999,
is valid.
IV. Was There An Abuse of Discretion?
We now examine the events of each relevant period in
petitioner’s case, which are described in the table below.
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