GOLDEN WEST FINANCIAL v. DEPT. OF REVENUE

No. 1D07-0135.

975 So.2d 567 (2008)

GOLDEN WEST FINANCIAL CORPORATION, World Savings & Loan Association, as Successor to Beach Federal Savings and Loan Association, Golden West Savings Association Service Company, World Mortgage Company, Commerce Investment Company of Shawnee, First Savings and Loan Shares, Incorporated, the 1901 Corporation, Atlas Securities, Incorporated, Atlas Advisers, Incorporated, Ohio Valley Service Corporation, Homeco Service Corporation, Steel Valley Management Group, Border City Consumer Corporation, Lynnwood Leasing and Mortgage Company, Incorporated, Lynnwood Financial Corporation, Pacific Holiday Development, First Consumer Service Corporation, World Savings Bank, SSB, World Savings Bank, FSB, (f/k/a Watchung Hills Bank for Savings), World Loan Company, WLC Company, and World Savings Association of Florida, and all Members of Golden West Financial Corporation's Affiliated Group of Companies, Successors, and Assigns, Appellants v. FLORIDA DEPARTMENT OF REVENUE, an Agency of the State of Florida, Appellee.

District Court of Appeal of Florida, First District.

February 19, 2008.


Attorney(s) appearing for the Case

David E. Otero, Peter O. Larsen, and Cynthia DeBula Baines of Akerman Senterfitt, Jacksonville, and Katherine E. Giddings of Akerman Senterfitt, Tallahassee, for Appellant.

Bill McCollum, Attorney General, and Charles Catanzaro, Assistant Attorney General, Tallahassee, for Appellee.


WEBSTER, J.

Appellants commenced an action in Leon County circuit court pursuant to section 72.011, Florida Statutes (2003), challenging the denial by the Department of Revenue of their application seeking refunds of state corporate income taxes paid for the years 1996 through 1999. Among other things, they alleged that Florida Administrative Code Rule 12C-1.013(14)(j), upon which the Department relied for its denial of the requested refunds, constituted "an invalid...

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