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DEPARTMENT OF REVENUE v. JOHNSTON

No. 63013.

442 So.2d 950 (1983)

DEPARTMENT OF REVENUE, Petitioner, v. Suzanne JOHNSTON, As Flagler County Property Appraiser, and Flagler County, Respondents.

Supreme Court of Florida.

December 15, 1983.

Attorney(s) appearing for the Case

Jim Smith, Atty. Gen. and J. Terrell Williams, Asst. Atty. Gen., Tallahassee, for petitioner.

Ronald E. Clark, Palatka, for respondents.

Talbot D'Alemberte of Steel, Hector & Davis, Miami, for City of Bunnell, Barry Ferguson, Mayor; Flagler County Chamber of Commerce; Flagler County Council on Aging, David Siegel, Chairman; Flagler County School Bd., Larry S. Goodemote, Chairman; ITT-Community Development Corp.; Palm Coast AARP Chapter and Palm Coast Kiwanis Chapter, G.B. Colesworthy, Jr.; Palm Coast Civil Ass'n, Warren Wolfert, Vice-President; Palm Coast Community Center, Carol King, President; Shangri-La Home Owners Ass'n, Elizabeth C. Neimeyer, President; and Woodlands at Palm Coast Ass'n # 1, Jerome Wunder, President, amicus curiae.

EHRLICH, Justice.

This cause is before the Court because of apparent conflict between the opinion of the district court below, State, Department of Revenue v. Johnston, 422 So.2d 935 (Fla. 5th DCA 1982), and opinions of two other district courts, State, Department of Revenue v. Markham, 426 So.2d 555 (Fla. 4th DCA 1982), and State, Department of Revenue v. Adkinson,

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