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Florida, tax collector for delinquent taxes owed on real property
are not obligations of a State or political subdivision, so that
interest paid on the certificates is not excluded from gross
income under section 103 for the taxable years 1990, 1991, and
1992. On May 28, 1998, we granted petitioner's motion for
reconsideration.
Introduction
On reconsideration, petitioner contends:2 (1) That tax
certificates issued by the Pasco County, Florida, tax collector
include both ad valorem real property taxes and special
assessments; (2) that section 1.103-1, Income Tax Regs., clearly
provides that certificates issued to enforce special assessments
against specific property, are, for the purposes of section 103,
obligations of the political subdivision; and (3) respondent’s
computation under Rule 155 has failed to deduct interest relating
to special assessments, from the composite interest payments,
which include interest on both special assessments and ad valorem
taxes, derived by the county as a single computation on the gross
charge against each parcel of land for which a tax certificate
was issued.
In his new arguments, petitioner relies on the following
language of section 1.103-1(b), Income Tax Regs.:
2 Petitioner makes other claims that lack even facial merit
and do not warrant reconsideration. Accordingly, they are
denied.
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