Joe Shelby Griffith - Page 4

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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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