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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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