Jerry D. Criner - Page 31

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          perfect a lien with respect to petitioner’s ownership interest in           
          the Claremore property.  At the trial in this case, petitioner              
          had testified that the Claremore property would remain titled in            
          the name of his deceased mother.  Under the circumstances                   
          involved in this case, the nominee NFTL was a reasonable                    
          collection procedure that enabled respondent to perfect a Federal           
          tax lien with respect to the Claremore property.  We conclude               
          therefore that the Appeals Office did not abuse its discretion in           
          upholding the filing of the nominee NFTL.                                   
          B.  Errors Not Raised at the Hearing                                        
               In an appeal from a notice of determination under sections             
          6320 and 6330, we ordinarily consider only those matters that               
          were raised in the hearing and/or considered in the notice of               
          determination.  Magana v. Commissioner, 118 T.C. 488, 493-494               
          (2002); Miller v. Commissioner, 115 T.C. 582, 589 n.2 (2000).  As           
          we stated in Magana v. Commissioner, supra at 493,                          
               it would be anomalous and improper for us to conclude                  
               that respondent’s Appeals Office abused its discretion                 
               under section 6330(c)(3) in failing to grant relief, or                
               in failing to consider arguments, issues, or other                     
               matter not raised by taxpayers or not otherwise brought                
               to the attention of respondent’s Appeals Office.  * * *                
               Petitioner raised several issues for the first time in his             
          petition that were not raised in the hearing or addressed in the            
          notice of determination:  (1) Whether the Appeals team manager              
          whose name appears on the notice of determination actually made a           
          determination as required by sections 6320 and 6330; (2) whether            





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