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ACCARDO v. BROWN

No. SC11-1445.

139 So.3d 848 (2014)

Leonard J. ACCARDO, et al., Petitioners, v. Gregory S. BROWN, etc., et al., Respondents.

Supreme Court of Florida.

Rehearing Denied May 22, 2014.

Attorney(s) appearing for the Case

Danny L. Kepner of Shell, Fleming, Davis & Menge, Pensacola, Florida; Talbot D'Alemberte and Patsy Palmer of D'Alemberte & Palmer, PLLC, Tallahassee, FL, for Petitioners.

J. Elliott Messer and Thomas Marshall Findley of Messer, Caparello & Self, P.A., Tallahassee, FL; Roy Van Andrews of Lindsay, Andrews & Leonard, Milton, FL, for Respondents.

Edward Paul Fleming and Randall Todd Harris of McDonald Fleming Moorhead of Pensacola, FL, for Amicus Curiae Beach Club Towers Homeowners Association, Inc.

Benjamin K. Phipps, II and Adam Schuyler Brink of Phipps & Howell, Tallahassee, FL, for Amicus Curiae Florida Association of Property Tax Professionals.

CANADY, J.

In this case, we consider whether the land and improvements on certain leaseholds in Navarre Beach on Santa Rosa Island that were created under long-term leases granted by Santa Rosa County, are subject to the intangible personal property tax rather than the ad valorem real property tax.1

In Accardo v. Brown, 63 So.3d 798 (Fla. 1st DCA 2011), the First District Court

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