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doctrine of equitable estoppel or as a second
examination of books and records. Sec. 7605(b), I.R.C.
3. Held, further, tax certificates sold by tax
collectors in Florida for delinquent taxes owed on real
property are not obligations of a State or political
subdivision thereof, and the interest paid thereon is
not excluded from gross income under sec. 103, I.R.C.
4. Held, further, interest paid on redemption of
tax sale certificates but not reported on P’s joint
returns is attributed to P by reason of his dominion
and control over amounts received on redemption of the
certificates and his failure to show that the income
belonged to or should be attributed to other persons.
5. Held, further, P is liable for accuracy-
related penalties for substantial understatements of
income tax. Sec. 6662, I.R.C.
John R. Hernandez, pro se.
Charles Baer, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge: Respondent determined the following
deficiencies and accuracy-related penalties in petitioner’s
Federal income tax:
Accuracy-Related Penalty
Year Deficiency Sec. 6662
1990 $7,680 $1,536
1991 7,139 1,428
1992 12,209 2,442
The issues for decision in this case are: (1) Whether the
statutory notice of deficiency was issued within the period of
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