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610 (2000); Goza v. Commissioner, supra at 181. We review the
remainder of respondent’s determination for an abuse of
discretion. Sego v. Commissioner, supra.
Petitioner challenged the tax and additions to tax on moral
and religious grounds. This argument is without merit. Adams v.
Commissioner, 170 F.3d 173 (3d Cir. 1999), affg. 110 T.C. 137
(1998). Petitioner otherwise conceded that the amounts
determined in the notices of deficiency are correct.
For the first time at trial, petitioner argued that
respondent did not mail the notices of deficiency to petitioner’s
last known address. Generally, we do not consider an issue that
is raised for the first time at trial. See 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).
Additionally, petitioner was aware of this issue before filing an
amendment to petition. Petitioner, however, chose not to amend
the petition to raise this issue. Thus, we do not consider it.
Petitioner also claimed that the period of limitations for
collection for 1988 and 1989 expired. We disagree. Tax may be
collected by levy if the levy is made within 10 years after the
assessment of the tax. Sec. 6502(a)(1). If a hearing is
requested under section 6330(a)(3)(B), the levy actions which are
the subject of the requested hearing and the running of any
period of limitations under section 6502 are suspended for the
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