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State or political subdivision. See id. In Hernandez I, because
of petitioner’s failure to present evidence in support of his
claims, we also rejected his argument that amounts there in issue
were income to his grandson or his brother Vincent, or his
brother’s wife Mildred, among others, rather than to him.
Subsequently, petitioner made a motion requesting that we
reconsider our holding in Hernandez I with respect to that
portion of interest paid on redemption of tax certificates that
was attributable to special assessments. In Hernandez v.
Commissioner, T.C. Memo. 1998-329 (Hernandez II), we declined to
alter the result we reached in Hernandez I.
Petitioner is a certified public accountant. For several
years, petitioner purchased at public auctions tax certificates
sold by Pasco County, Florida, pursuant to Fla. Stat. Ann. sec.
197.432 (West 1989 & Supp. 1997). Pasco County and other
counties in Florida sell the certificates for amounts equal to
delinquent property taxes, interest accrued thereon, and other
costs and charges owed by property owners to the county. See
Hernandez I. The certificates provide a means for Florida
counties to fund current government expenditures by transferring
the indebtedness incurred by property owners for their property
tax delinquencies to the purchasers of the tax certificates. See
id. The certificates also provide a mechanism for eventual
collection of the delinquent taxes out of the property against
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