Rainey v. Department of Revenue

RAWLS, Judge.

Petitioners, D. I. Rainey, Jr., et al., having been aggrieved by final agency action, seek review of the order of respondent, Department of Revenue, assessing documentary stamp taxes and penalty. The primary issue, as framed by the hearing officer, is: Whether the transaction evidenced by the written instrument is taxable under the provisions of Sections 201.01 and 201.08, Florida Statutes?

On February 28, 1974, petitioners, with the exception of two individuals, executed and delivered to The Lewis State Bank a promissory note in the amount of $405,-000.00 and a mortgage securing…