DEPARTMENT OF REV. v. AMREP CORP.

No. 50549.

358 So.2d 1343 (1978)

DEPARTMENT OF REVENUE, Consisting of Ruebin O'd. Askew, As Governor of Florida, Bruce A. Smathers, As Secretary of State, Robert L. Shevin, As Attorney General, Gerald A. Lewis, As Comptroller, Philip F. Ashler, As Treasurer, Doyle Conner, As Commissioner of Agriculture, and Ralph Turlington, As Commissioner of Education; and J. Ed Straughn, As Executive Director of the Florida Department of Revenue, Appellants, v. AMREP CORPORATION, an Oklahoma Corporation, Silver Springs Shores, Inc., a Florida Corporation, Silver Springs Golf and Country Club, Inc., a Florida Corporation, Marion Realty, Inc., a Florida Corporation, Holiday Shores Tours, Inc., a Florida Corporation, Mid-Florida Lakes, Inc., a Florida Corporation, Florida Ridge Utilities Corp., a Florida Corporation, Panorama Inn of Florida, Inc., a Florida Corporation, Rolling Greens, Inc., a Florida Corporation, and Amrep Construction Corp., a New Mexico Corporation, Appellees.

Supreme Court of Florida.

As Modified On Denial of Rehearing May 25, 1978.


Attorney(s) appearing for the Case

Robert L. Shevin, Atty. Gen., and E. Wilson Crump, II, Asst. Atty. Gen., Tallahassee, for appellants.

Parker D. Thomson and Susan W. Diner of Paul & Thomson, Miami, for appellees.


On Petition For Clarification

SUNDBERG, Justice.

This appeal tests the validity of the exemption of intercompany accounts receivable from the intangible personal property tax afforded to domiciliary corporate "affiliated groups" under Section 199.023(7), Florida Statutes (1975), when measured against the Equal Protection Clause of the United States Constitution.

The appellees in this cause are Amrep Corporation, an Oklahoma corporation having...

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