Cir

In an action seeking judicial review of the IRS’s adjustment of a partnership’s tax return, the tax court has jurisdiction, pursuant to 26 U.S.C. § 6226 (d)(1), to “consider” an assertion by any of the partners that the applicable statute of limitations has expired for that particular partner. Here, a partner made such an assertion, and the tax court rejected it, holding that the limitations period re mained open as to the partner. The partner seeks reversal, arguing that although the tax court had jurisdiction to accept his assertion, it lacked jurisdiction to reject it. We hold that the tax court had jurisdiction to reject the partner’s assertion of the statute of limitations, and we affirm.

FACTS AND PRIOR PROCEEDINGS

In 1998, Appellant Marcus Katz entered into two “collar” option contracts covering stock shares he owned. Katz terminated the collars in September of 1999, which generated a credit of $198,000. In October of 1999, Katz contributed stock to MK Hillside Partners (MK Hillside), a partnership between Katz and his wholly owned corporation, MK Hillside Investors, Inc. Katz also contributed real estate to the partnership. The partnership then sold the stock…