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in relation to the other participants in the auction with respect
to the rate of interest accruing thereafter that he would accept;
this voluntary bargain did not change or otherwise affect the
amount of the payment received by the county from petitioner or
that the county would have received from any other potential
purchaser, which was the face amount of the certificate.
Accordingly, the decision in this case turns, not on whether
petitioner voluntarily contracted with the county, which he did,
but rather on the antecedent question of whether a Florida tax
certificate is an obligation of a State or political subdivision
within the meaning of section 103(c)(1). Newman v. Commissioner,
68 T.C. 433 (1977); Kansas City S. Ry. Co. and Affiliated Cos. v.
Commissioner, supra.
In Barrow v. Commissioner, T.C. Memo. 1983-123, we discussed
the nature of tax certificates under Florida law, the salient
points of which remain unchanged. We cited Florida court
opinions that characterize tax certificates as nothing more than
evidence of a lien created solely to facilitate expedient
enforcement of the obligation of a landowner to pay taxes
lawfully assessed. Beebe v. State Supreme Court, 151 So. 298,
299 (Fla. 1933); see also Smith v. City of Arcadia, 185 So. 2d
762, 767 (Fla. Dist. Ct. App. 1966) (“Tax certificates are only a
means of evidencing unpaid taxes and to enable the sale thereof
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