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liable for the accuracy-related penalties under section 6662(a)
for tax years 1995, 1996, and 1997.2
Background
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time of filing his
petition, petitioner resided in Saint Leo, Florida.
Prior to his retirement, petitioner was a certified public
accountant, and he owned an accounting service. Petitioner’s
wife, Oneta Hernandez (Mrs. Hernandez), became ill in 1990 and
died in 1995.
During the years at issue, petitioner purchased numerous tax
certificates sold by Pasco County, Florida (tax certificates).
For a thorough discussion regarding the details of the tax
certificates, see Hernandez v. Commissioner, T.C. Memo. 1998-46.
Petitioner received checks for the interest paid on the
redemption of the certificates. Petitioner and Mrs. Hernandez
negotiated the checks and deposited the amounts into a credit
union account. Petitioner also owned a house in the Bahamas
during the years in issue.
2 The notices of deficiency contain adjustments to
petitioner’s Social Security income, itemized deductions, and net
operating losses. These are computational adjustments which will
be affected by the outcome of the other issues to be decided, and
we do not separately address them.
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