- 12 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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