Florida Manufactured Housing Ass'n v. Department of Revenue

Florida Manufactured Housing Association, Inc. (FMHA) appeals a final administrative order of the Division of Administrative Hearings which denied the petition of FMHA to declare proposed Florida Administrative Code Rules 12D-6.001 and 12D-6.0021 to be *627invalid. FMHA argues that section 193.075, Florida Statutes (1991), violates the prohibition against ad valorem taxation of mobile homes set forth in article VII, section 1(b) of the Florida Constitution. FMHA also argues that the Department of Revenue (DOR) has exceeded its rulemaking authority and that the rules are arbitrary and capricious.…