CAMPBELL, Judge.
This appeal is brought by the defendant in the trial court, the Collier County Tax Assessor, and requires us to determine whether certain improvements constructed by appellees were "substantially completed" as of January 1, 1978. We conclude that they were and reverse the trial court's determination to the contrary.
Appellees are developers of "regional" shopping malls. In 1976, they applied to the city of Naples for a building permit to construct...
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