- 31 - 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) whetherPage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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