SHEPHERD, J.
This is an appeal by the Miami-Dade County Property Appraiser and the Florida Department of Revenue from a final summary judgment, bestowing an exemption from ad valorem taxation upon the owners of residential real estate in Miami-Dade County on the basis the property is the "permanent residence" of their minor children, who are "naturally dependent" upon them within the meaning of article VII, section 6(a) of the Florida Constitution.
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