PER CURIAM.
The Department of Revenue appeals the trial court's order granting final summary judgment in favor of Ruehl No. 925, LLC, and denying its motion for partial summary judgment. Because the parties stipulated that there were no genuine issues of material fact, the only issue below was whether Ruehl or the Department was entitled to judgment as a matter of law. See Fla. R. Civ. P. 1.510(c); USCardio Vascular, Inc. v. Dep't of Revenue,
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