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mother owned the Claremore property and that, therefore, the
nominee NFTL was unlawful. Petitioner and Jeannie McLelland
explained that their mother had died without a will, that she had
left the property to her six children, that her estate had not
gone through probate, and that the property would remain in her
name forever. Petitioner conceded, however, that he owned a one-
sixth interest in the Claremore property by virtue of his
mother’s death. At the hearing, Mr. Penny again asked for
documentation showing the ability of petitioner’s mother to
purchase the Claremore property in 1987 without the encumbrance
of a mortgage, but petitioner did not produce the requested
documentation at the hearing or at any time after the hearing.
Petitioner also argued at the hearing that the assessments
against him for 1990 through 1993 were invalid because he had
rescinded his signature on the Form 870. Petitioner did not
raise any spousal defenses or propose any specific collection
alternatives during the hearing.6
On March 28, 2002, respondent’s Appeals Office issued a
notice of determination in which it determined the following:
1. All legal and administrative procedures for filing a
nominee NFTL were met.
2. The Appeals officer had had no prior involvement with
6Petitioner had previously filed two offers in compromise
which respondent either rejected or requested be withdrawn.
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