- 2 - effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Respondent determined a deficiency in petitioner’s 1994 Federal income tax of $4,706 and an accuracy-related penalty under section 6662(a) of $941. The issues for decision are: (1) Whether interest income realized upon the redemption of tax certificates is attributable to petitioner, and (2) whether petitioner is liable for an accuracy-related penalty under section 6662(a).1 Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioner resided in Saint Leo, Florida, when the petition in this case was filed. Petitioner has been in this Court before in a case involving substantially the same facts as those presented here, Hernandez v. Commissioner, T.C. Memo. 1998-46 (Hernandez I). In Hernandez I, we held that interest paid on the redemption of tax certificates sold by Pasco County, Florida, for delinquent taxes owed on real property is not excluded from gross income under section 103 because the tax certificates are not obligations of a 1 In the notice of deficiency, respondent determined that petitioner was not entitled to the itemized deductions he claimed on his 1994 Federal income tax return. In lieu of the itemized deductions, respondent allowed petitioner a standard deduction. This adjustment is a computational adjustment that is dependent upon our determination whether petitioner failed to report taxable interest income.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011