John R. Hernandez - Page 2

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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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