- 4 - Theresa Collins (Mrs. Collins).2 Mrs. Hernandez died prior to respondent’s issuance of the statutory notice of deficiency.3 For several years, petitioner purchased at public auction tax certificates sold by Pasco County pursuant to Fla. Stat. Ann. sec. 197.432 (West 1989 & Supp. 1997). Pasco County and other counties in Florida sold certificates for amounts equal to delinquent property taxes, interest accrued thereon, and other costs and charges owed by property owners to the county. The certificates serve as a means by which the counties fund current government expenditures by transferring the indebtedness incurred by property owners for their property tax delinquencies to the purchasers of the tax certificates. They also provide a mechanism for eventual collection of the delinquent taxes out of the property against which the assessment was made, either through redemption of the certificates or eventual sale of the property. Potential purchasers bid at auction to purchase tax 2 The record also refers to Mrs. Collins as “T.H. Coleman”, her name from a subsequent marriage. 3 On May 10, 1996, respondent issued a statutory notice of deficiency to petitioner and Mrs. Hernandez, pursuant to joint returns they filed for the years in issue. On Aug. 9, 1996, petitioner timely filed a petition with this Court. On Sept. 30, 1996, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Oneta B. Hernandez and to Change Caption. Petitioner was served with that motion but did not respond to show that the petition was filed by a fiduciary entitled to institute a case on behalf of Mrs. Hernandez. On Nov. 5, 1996, this Court granted respondent’s motion, dismissing Mrs. Hernandez as a party to this case.Page: Previous 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