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ST. DEPT. OF REVENUE v. MIAMI NAT. BK.

No. CC-187.

354 So.2d 84 (1977)

STATE of Florida DEPARTMENT OF REVENUE, Appellant, v. MIAMI NATIONAL BANK, a National Banking Association, and Southeast First National Bank of Miami Springs, a National Banking Association, Appellees.

District Court of Appeal of Florida, First District.

December 23, 1977.

Attorney(s) appearing for the Case

Robert L. Shevin, Atty. Gen., and Caroline C. Mueller, Asst. Atty. Gen., for appellant.

Harvie S. Duval of Papy, Levy, Carruthers & Poole, Coral Gables, James D. Little and Andrew J. Mirabito, of Frates, Floyd, Pearson, Stewart, Proenza & Richman, Miami, for appellees.

RAWLS, Judge.

We are here confronted with a documentary stamp tax assessment by appellant, Department of Revenue. The following factual situation was given as an example and agreed upon by the parties:

A borrows $10,000 from the bank. A signs a promissory note for $10,000 and affixes documentary stamps thereto representing the full $10,000. Subsequently, A borrows an additional $5,000 from the bank. A signs a promissory note for $15,000 —...

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