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AURORA GROUP, LTD. v. DEPT. OF REVENUE

No. 85-2387.

487 So.2d 1132 (1986)

The AURORA GROUP, LTD., Appellant, v. DEPARTMENT OF REVENUE, State of Florida, Appellee.

District Court of Appeal of Florida, Third District.

Rehearing Denied June 2, 1986.

Attorney(s) appearing for the Case

Feuer, Lustig & Schillinger and Lee H. Schillinger, for appellant.

Jim Smith, Atty. Gen., and J. Terrell Williams and Edwin A. Bayo, Asst. Attys. Gen., for appellee.

Before HENDRY, HUBBART and DANIEL S. PEARSON, JJ.

DANIEL S. PEARSON, Judge.

This case involves the ad valorem taxation of a $2,500,000 promissory note executed by The Aurora Group, Ltd. (Aurora) secured by a mortgage of Aurora's 99-year leasehold interest in certain real property. At Aurora's request, the Department of Revenue of the State of Florida issued a Declaratory Statement concerning the appropriate tax to be imposed on the note. To Aurora's dismay, the Department ruled

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