relevant factors that the bankruptcy court should have considered by failing to raise the argument before the bankruptcy court. See O’Guinn v. Lovelock Corr. Ctr., 502 F.3d 1056, 1063 n. 3 (9th Cir.2007) (<HOLDING>). Although the BAP declined review on the
holding that issues not raised before a district court are waived on appeal holding that arguments not raised before the trial court are waived holding that arguments not raised in the opening brief are waived holding arguments not raised on appeal waived holding that arguments not raised below are waived for appeal