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arbitrary.
(f) Respondent erred by determining that all
applicable laws and administrative procedures to
support his nominee lien action against Petitioner had
been met, although he neither considered the
applicability of the laws of the State of Oklahoma, nor
considered Petitioner’s status under those laws, with
respect to the real property that is the subject of his
nominee Notice of Federal Tax Lien.
(g) Respondent erred by determining that
Petitioner had not proposed reasonable collection
alternatives to Respondent’s lien action.
(h) Respondent erred by not considering, exploring,
or eliciting from Petitioner, what collection actions
less intrusive than lien action would balance the
government’s need to efficiently collect the tax
liabilities at issue with Petitioner’s legitimate
concern that the collection action be made by the
method least intrusive to him.
(i) With respect to the tax liability for the year
1993, Respondent abused his discretion by determining
it was appropriate to cause the filing, against certain
real property, of a nominee Notice of Federal Tax Lien
with respect to Petitioner, when he had already caused
the filing of a Notice of Federal Tax Lien against
Petitioner for the year 1993.
(j) Respondent abused his discretion by asserting
against Petitioner a nominee theory with respect to
specific real property, the existence and ownership of
which was known to Respondent at least four years prior
to the filing of his nominee Notice of Federal Tax
Lien, yet which specific real property was never deemed
by him to be the property of Petitioner.
The errors identified in paragraphs (a), (b), (i), and (j) were
not raised by petitioner at the hearing and were not considered
by the Appeals Office in its notice of determination.
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