- 6 - 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.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