- 5 - the amount of $27,703 from redeemed Escambia County tax certificates. Petitioners offered no evidence or argument disputing respondent’s determination that they received $433 in interest from Bay County, Florida, in 1996, and we accordingly find that they received such interest.4 Having concluded that petitioners received $28,136 of interest income in 1996 from Escambia and Bay Counties, Florida, we must decide whether any portion of this amount may be excluded from petitioners’ gross income. Petitioners argue that the interest reflected on Forms 1099 from Bay County and Escambia County, Florida, as interest earned on redeemed tax certificates is tax-exempt interest under section 103. In general, subsections (a) and (c)(1) of section 103 exclude from gross income the interest earned on specified State or local bonds, provided such bonds represent an obligation of a State or its political subdivisions. This Court has previously held that interest received on account of taxpayers’ holding Florida tax certificates that are redeemed is not excluded from gross income under section 103 because the certificates are not obligations of the State of 4 As petitioners neither asserted a reasonable dispute nor introduced credible evidence with respect to their receipt of the interest income as determined by respondent, the burden of proof does not shift to respondent in this case. See secs. 6201(d), (effective for court proceedings on or after July 30, 1996), 7491(a)(effective in connection with examinations commencing after July 22, 1998).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011