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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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