- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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