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section 7605(b) does not prevent the Commissioner from reviewing
a taxpayer’s income tax return after inspecting his books and
records because a “review of the Form 1040, and accompanying
schedules, does not constitute an inspection of a taxpayer’s
‘books of account.’” Curtis v. Commissioner, 84 T.C. 1349, 1351
(1985) (quoting Benjamin v. Commissioner, 66 T.C. 1084, 1097
(1976), affd. 592 F.2d 1259 (5th Cir. 1977)). We have found
nothing in the record to indicate that, for tax year 1990, a
second examination of petitioner’s books and records occurred
within the meaning of section 7605(b). Because we find that no
violation of section 7605(b) occurred, we do not reach whether
invalidation of the deficiency notice is the proper remedy for
such a violation. Curtis v. Commissioner, supra at 1356.
Issue 3. Income From the Redemption of Pasco County, Florida,
Tax Certificates Is Not Excluded From Gross Income Under Section
103
Petitioner contends that interest received on redemption of
Florida tax certificates purchased from the tax collector of
Pasco County, Florida, is excluded from gross income under
section 103(a) as interest earned on State or local bonds.
Petitioner argues that tax certificates are State or local bonds
voluntarily entered into because they are contracts, between
Pasco County and the purchasers, and thus obligations of Pasco
County, a political subdivision of the State of Florida.
Respondent argues that the tax certificates are not obligations
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