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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.
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