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FIRST NAT. BANK OF BIRMINGHAM v. DEPT. OF REVENUE

No. HH-335.

364 So.2d 38 (1978)

FIRST NATIONAL BANK OF BIRMINGHAM, a Federally Chartered Banking Institution with Its Principal Place of Business in Birmingham, Alabama, Petitioner, v. DEPARTMENT OF REVENUE of the State of Florida, Respondent.

District Court of Appeal of Florida, First District.

Rehearing Denied December 6, 1978.

Attorney(s) appearing for the Case

William Guy Davis, Jr. of Beggs & Lane, Pensacola, for petitioner.

Robert L. Shevin, Atty. Gen., E. Wilson Crump, II, Asst. Atty. Gen., for respondent.

ERVIN, Judge.

First National Bank seeks review of a final order of the Department of Revenue approving an assessment of intangible personal property taxes upon two notes held by the Bank which were secured by mortgages on leaseholds upon real estate in Santa Rosa Island.

In 1971, the Okaloosa Island Authority, a governmental agency, leased certain real property on Santa Rosa Island in Okaloosa County to the Okaloosa Development Corporation for a term of 99...

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