John R. Hernandez - Page 9

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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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