John R. Hernandez - Page 1

                                 T.C. Memo. 1998-46                                   

                               UNITED STATES TAX COURT                                

                          JOHN R. HERNANDEZ, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 17244-96.                Filed February 5, 1998.            

                    Tax certificates are sold at public auction by the                
               tax collector for Pasco County, Florida, for an amount                 
               equal to delinquent real property taxes, interest                      
               accrued thereon, and other costs and charges owed by                   
               the real property owner.  Purchasers bid for the tax                   
               certificates in terms of the rate of interest to be                    
               paid on the face amount of the certificate.  The tax                   
               certificates must be either redeemed or converted into                 
               a tax deed within 7 years of being sold at auction.  P                 
               purchased tax certificates from the Pasco County tax                   
               collector that were redeemed in tax years 1990, 1991,                  
               and 1992 for the face amount of each certificate plus                  
               accrued interest at the rate bid.                                      
                    1.  Held:  The statutory notice of deficiency was                 
               issued within period of limitations as properly                        
                    2.  Held, further, respondent is not estopped from                
               issuing a statutory notice of deficiency by either the                 

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