- 17 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011