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based. In Carey v. Winslow, 122 P. 174 (Okla. 1912), the
Oklahoma Supreme Court found that, although certain stock was
titled in the name of a third party, the judgment debtor, who had
previously held legal title, had never parted with the beneficial
ownership of the stock. The court held that the stock remained
subject to the judgment debtor’s debts. See also Baxley v.
Timms, 316 P.2d 871 (Okla. 1957), in which the Oklahoma Supreme
Court acknowledged that it was possible for a person to hold bare
legal title to real property while the beneficial interest in the
property remained in another.
We hold, therefore, that the Appeals Office did not abuse
its discretion in determining that a nominee NFTL was a valid and
appropriate collection procedure in this case.
c. Nominee Lien Procedures
Petitioner argues that, even if the use of a nominee NFTL is
an appropriate collection procedure, respondent did not follow
required administrative procedures in obtaining approval to file
the nominee NFTL. Specifically, petitioner contends that
respondent skipped a required review step when Revenue Officer
Baustert forwarded his memorandum requesting authorization to
file the nominee NFTL directly to Counsel.
The Internal Revenue Manual (IRM) requires that, before a
nominee NFTL is filed, the Collection Office must obtain written
approval from Counsel. 2 Administration, Internal Revenue Manual
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