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limitations; (2) whether respondent is estopped from issuing the
notice; (3) whether interest income from the redemption of tax
certificates issued by Pasco County, Florida, is excluded from
gross income under section 103;1 (4) the extent to which receipts
from the redemption of the tax certificates are attributable to
petitioner; and (5) whether petitioner is liable for accuracy-
related penalties under section 6662(d) for substantial
understatements of income tax. We sustain respondent’s
determinations in all respects.
FINDINGS OF FACT
The parties stipulated some of the facts, which, with the
corresponding exhibits, are so found and incorporated herein by
reference. Petitioner resided in Saint Leo, Florida, at all
times relevant to this case.
During the tax years at issue, petitioner was a certified
public accountant who was the business manager of an S
corporation and operated an accounting service that prepared tax
returns for others. Petitioner and Oneta Hernandez (Mrs.
Hernandez) had two daughters, Deborah H. Craig (Mrs. Craig) and
1 All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
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