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
extended.
2. Held, further, respondent is not estopped from
issuing a statutory notice of deficiency by either the
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011