John R. Hernandez - Page 4

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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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