John R. Hernandez - Page 13

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               We hold that the tax certificates issued by Pasco County to            
          petitioner are not covered by section 1.103-1(b), Income Tax                
          Regs., to any extent.  We reaffirm that they are not obligations            
          of a political subdivision for purposes of section 103.                     
          Accordingly, none of the interest earned on the Pasco County tax            
          certificates, whether attributable to special assessments or to             
          ad valorem property taxes, is exempt from Federal income tax                
          under section 103.                                                          
               For the reasons stated, we decline to alter the result                 
          reached in our opinion reported at Hernandez v. Commissioner,               
          T.C. Memo. 1998-46.                                                         
               To reflect the foregoing,                                              

          An appropriate order                                                        
          will be issued.                                                             

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