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we generally do not consider an issue that is raised for the
first time at trial. See, e.g., 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). Respondent has offered
no explanation for not raising the issue of petitioner’s
noncompliance earlier. We do not consider this issue, nor does
it affect the outcome of this case.
Doubt as to Collectibility
The Secretary may compromise a tax liability for doubt as to
collectibility when “the taxpayer’s assets and income are less
than the full amount of the assessed liability.” Sec.
301.7122-1(b)(2), Proced. & Admin. Regs. Respondent determined
that the total value of petitioner’s interests in real property
exceeded the amount of his unpaid tax liabilities. At trial,
petitioner stated he “had no problem” with respondent’s
determination with respect to his real property interests. He
also conceded that he had sufficient assets to pay his tax
liabilities for the years at issue. Accordingly, he is not
entitled to compromise his tax liabilities on the basis of doubt
as to collectibility.
Effective Tax Administration
The Secretary may compromise a liability on the ground of
effective tax administration when: (1) Collection of the full
liability will create economic hardship; or (2) exceptional
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