We will not consider issues raised first on brief and not raised in the pleadings. Rollert Residuary Trust v. Commissioner, 80 T.C. 619, 636 (1983), affd. on other grounds 752 F.2d. 1128 (6th Cir.1985); Estate of Kleemeier v. Commissioner, 58 T.C. 241, 250 (1972). Petitioners were not afforded the opportunity to address that issue; therefore, they did not attempt to show that section 6662(b)(2) should not be applied.
Eleanor C. Shomaker, supra at 201. See also Estate of Lyla B. Kleemeier, 58 T.C. 241 (1972). Petitioner on brief also claimed that one-half of the family allowance must be taken as a deduction in determining Raymond's estate tax and a reconsideration of Raymond's estate tax and its effect on Isabelle's return is in order.
Accordingly, we hold that such claim is untimely and cannot be considered in deciding this case. Estate of Lyla D. Kleemeier, 58 T.C. 241(1972). Although it will be necessary to recompute the amount of the charitable contribution as a result of the additional administrative expenses that have been incurred in this litigation, the value of such contribution should be computed by using the same method as was used on the return.