§3462

7122(c)(1) as added by section 3462(a) of RRA 1998 (Public Law No .

ts that a taxpayer must meet to qualify for a compromise on the basis of effective tax administration. Petitioner bases his challenge on changes made to sec. 7122 by the Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3462(a) and (c)(1), 112 Stat. 764, 766. See H. Rept. 105-599, at 287-289 (1998), 1998-3 C.B. 747, 1041-1043 (addressing effective tax administration). That argument is raised too late for consideration. See Rule 334(b)(4); Aero Rental v. Commiss

, 64 Fed. Reg. 39024 (July 19, 1999).8 Petitioner bases both offers on doubt as 8 Sec. 7122(c) is effective only for offers-in-compromise submitted after July 22, 1998. Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3462, 112 Stat. 764. Sec. 301.7122-1T(b), Temporary Proced. & Admin. Regs., 64 Fed. Reg. 39024 (July 19, 1999), is effective for offers submitted after July 19, 1999, but sec. 301.7122-1, - 10 - to collectibility. Section 7122(c) provides the sta

ent’s computations and conclude that they are reasonable. McCorkle v. Commissioner, T.C. Memo. 2003-34; Schulman v. Commissioner, T.C. Memo. 2002-129. The passage of the Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3462(a), 112 Stat. 764, which added section 7122(c) to the Code, resulted in the issuance of new regulations substantially changing offer-in- compromise procedures found in section 7122. The traditional grounds for compromise had been doubt as t