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Petitioner purchased tax certificates with his own funds and
with borrowed funds.7 Although the Pasco County tax collector
issued the certificates purchased by petitioner in several
combinations of names, they all listed either petitioner or
Mrs. Hernandez as one of the coholders. For each certificate
redeemed, the tax collector issued checks made out to the same
persons listed as certificate holders. Some certificates were
issued to Mrs. Hernandez “et al.” Other certificates were issued
to Mrs. Hernandez and one or more other persons who were listed
on the certificates as alternate holders. Some certificates were
issued to petitioner and one or more alternate holders. The rest
of the certificates were issued to petitioner and Mrs. Hernandez
as coholders.8
Each time one of the certificates at issue was redeemed, the
tax collector paid an amount by check that included both the
principal and interest accrued at the rate bid for the purchase
of the certificate to the persons listed as coholders of that
certificate. In each tax year at issue, the tax collector issued
7 Petitioner’s daughter Mrs. Craig may also have been a
source of funds, although whether, and the extent to which,
she bought tax sale certificates is unclear from the record.
However, the proceeds from the redemption of all the tax
certificates at issue were deposited into an account in
Mrs. Hernandez’ name.
8 Petitioner also bought certificates in the name of Holy
Ghost Fathers, Inc., a religious order, which were redeemed in
each of the tax years in issue. Respondent determined in the
statutory notice of deficiency that none of the interest income
from those certificates was income to petitioner.
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