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WALDEN v. UNIV. OF S. FLA. FOUNDATION

Nos. 74-1427 and 74-1434.

328 So.2d 460 (1976)

R.R. WALDEN, As Tax Assessor of Hillsborough County, Appellant, v. UNIVERSITY OF SOUTH FLORIDA FOUNDATION, HILLSBOROUGH COUNTY, a Political Subdivision of the State of Florida, and K.C. Bullard, As Tax Collector of Hillsborough County, Florida, Appellees. DEPARTMENT OF REVENUE for the STATE of Florida, Appellant, v. UNIVERSITY OF SOUTH FLORIDA FOUNDATION, HILLSBOROUGH COUNTY, a Political Subdivision of the State of Florida, and K.C. Bullard, As Tax Collector of Hillsborough County, Florida, Appellees.

District Court of Appeal of Florida, Second District.

March 12, 1976.

Attorney(s) appearing for the Case

Brooks P. Hoyt, Macfarlane, Ferguson, Allison & Kelly, Tampa, for appellant Tax Assessor.

Robert L. Shevin, Atty. Gen., and Stephen E. Mitchell, Asst. Atty. Gen., Tallahassee, for appellant Dept. of Revenue.

Richard N. Stein, Gibbons, Tucker, McEwen, Smith, Cofer & Taub, Tampa, for appellee Foundation.

HOBSON, Judge.

This appeal is from a final summary judgment wherein the trial court held that the appellee, University of South Florida Foundation, was an educational institution within the purview of Chapter 196, Florida Statutes. The Foundation owned two parcels of property, one of which was immediately adjacent to the University of South Florida campus and improved by two 2-story apartment buildings. As to this parcel

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