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jurisdiction, respondent contends, the Court should not address
the issue in this case because it was not raised before the
Appeals office. Additionally, respondent contends that, because
the value of the pension plan does not affect the question of the
validity of the lien, discussed above, but could only affect
collection alternatives, we should review the Appeals officer’s
determination that collection should proceed only for abuse of
discretion. Finally, respondent argues that the Court should not
address the issue because the liens could potentially affect
other assets owned by petitioner at the time the bankruptcy
proceeding was commenced, that the value may be changed by the
time of a levy that has not yet occurred, and that petitioner’s
former wife is not a party to this proceeding.
Petitioner is seeking a determination as to the amount of
petitioner’s pension subject to the liens filed in 1996 and,
implicitly, a determination that no other assets of petitioner
are subject to those liens. This argument was not made before
the Appeals officer during the hearing because no alternatives to
collection were raised. We agree with respondent that it would
be inappropriate to anticipate, determine, and limit the scope of
the liens on the record in this case. There may be circumstances
under which the amount that is subject to the lien is necessarily
a part of our determination of whether there was an abuse of
discretion in rejecting collection alternatives. This is not
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