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Claremore property. Several of the errors involve arguments that
were not raised at the hearing or considered by the Appeals
Office in its notice of determination. We shall divide
petitioner’s alleged errors into two categories--those that were
raised at the hearing and addressed in the notice of
determination and those that were not--and evaluate them
accordingly. Because petitioner concedes that he is not
contesting the underlying tax liabilities, we shall review the
Appeals Office’s determination for abuse of discretion. Id.
A. Errors Raised at the Hearing
The errors listed in the amended petition that were raised
by petitioner, either explicitly and implicitly, at the hearing
and/or addressed in the notice of determination are as follows:
1. Respondent erred in determining that the hearing officer
had no prior involvement with respect to the unpaid tax at issue
in this proceeding.
2. Respondent erred in determining that the requirements of
applicable laws and administrative procedures relative to the
issuance and filing of the nominee NFTL had been satisfied and
that the nominee NFTL was valid.
3. Respondent erred by not considering reasonable
collection alternatives to respondent’s nominee NFTL and by
concluding that the filing of the nominee NFTL balanced
respondent’s need for efficient collection of taxes with
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