Uscardio Vascular, Inc. v. Florida Department of Revenue

At issue in the present case is nothing more or less than whether “base rent”— unambiguously defined as such for purposes of the leases in question — is subject to the excise tax levied by section 212.031, Florida Statutes. For the three tax years in dispute, the statute provided (as it still provides):

[A] tax is levied in an amount equal to 6 percent of and on the total rent ... charged for ... real property [like appellant’s] ... The total rent ... shall include base rent....

§ 212.031(l)(c), Fla. Stat. (2001). The present case poses a straightforward question of statutory construction,…