HAVERFIELD, Chief Judge.
Hialeah, Inc. (Hialeah) and Southeast First National Bank (Southeast), the petitioners, appeal from a final agency decision by the Governor and the Cabinet of the State of Florida, acting as head of the Department of Revenue, in affirming the recommendations of a Department hearing officer that Hialeah owed additional documentary stamp tax in connection with its purchase of Hialeah Race Track and assumption of an existing mortgage.
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