Phillip and Gladies Aaron - Page 17

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          penalties or proposals of collection alternatives if they were              
          not raised by the taxpayer at the section 6330 hearing or                   
          otherwise brought to the attention of the Appeals Office.  Magana           
          v. Commissioner, 118 T.C. 488, 493 (2002); Miller v.                        
          Commissioner, 115 T.C. 582, 589 n.2 (2000); Sego v. Commissioner,           
          114 T.C. at 612.  Generally, we do not consider issues that are             
          raised for the first time at trial or on brief, and we decline to           
          do so in this case.  Foil v. Commissioner, 92 T.C. 376, 418                 
          (1989), affd. 920 F.2d 1196 (5th Cir. 1990); Markwardt v.                   
          Commissioner, 64 T.C. 989, 997 (1975).  Petitioner has failed to            
          raise a spousal defense, make a valid challenge to the                      
          appropriateness of respondent’s intended collection action, or              
          offer alternative means of collection.  These issues are now                
          deemed conceded.  See Rule 331(b)(4).                                       
               In reaching all of our holdings herein, we have considered             
          all arguments made by the parties, and to the extent not                    
          mentioned above, we find them to be irrelevant or without merit.            
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          













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