T.C. Memo. 1998-329 UNITED STATES TAX COURT JOHN R. HERNANDEZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 17244-96. Filed September 21, 1998. The Court granted P's Motion for Reconsideration of Hernandez v. Commissioner, T.C. Memo. 1998-46, which held that interest received on redemption of tax certificates sold at public auction by Pasco County, Florida, for nonpayment of property taxes was not excluded from P's gross income under I.R.C. sec. 103(a) as interest earned on State or local obligations. The ground of decision was that tax certificates are not issued by a State or political subdivision in exercise of its sovereign borrowing power and therefore are not obligations of a State or political subdivision for purposes of I.R.C. sec. 103. On reconsideration, P asserts that the portion of the interest paid on redemption of tax certificates that is attributable to special assessments (in contrast to ad valorem taxes) is excluded from hisPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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