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child filed an income tax return reporting any portion of such
interest, nor did any other individual report any such amount on
any of his income tax returns as either income or tax-exempt
interest.
“V.H. Hernandez” and “M.L. Hernandez” were petitioner’s
brother, Vincent, and his brother’s wife, Mildred, respectively.
For tax year 1992, respondent did not include $1,070.18 in
adjustments to petitioner’s income from interest received in
redemption of tax certificates held by petitioner jointly with
Vincent or Mildred Hernandez. With respect to amounts reported
on Forms 1099 bearing their names and petitioner’s name for tax
years 1990 and 1991, neither Vincent nor Mildred Hernandez filed
an income tax return that reported interest from the redemption
of the tax certificates in question as either income or tax-
exempt interest. Vincent and Mildred Hernandez signed a document
dated February 27, 1984, that purported to appoint petitioner as
“Attorney-in-fact” to “represent them before the Tax Collector *
* * of Pasco County”. This document had no expiration date.
“F.E. Reaves” was Mrs. Hernandez’ mother, who died prior to
trial at a time not indicated in the record. Ms. Reaves did not
file an income tax return in any year at issue that reported
amounts of interest earned in redemption of Pasco County tax
certificates as either income or tax-exempt interest.
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