John R. Hernandez - Page 6

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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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