NCNB National Bank of Florida v. Department of Revenue

THREADGILL, Judge.

Appellants challenge the trial court’s finding that a renewal note did not qualify for exemption from documentary stamp tax under provisions of section 201.09, Florida Statutes (1983). We conclude that the note satisfied the conditions for exemption and reverse.

In 1973, Culverhouse borrowed $10,750,-000 from Housing Investment Corporation of Florida and issued a mortgage note (note 1) for that amount secured by real property located in Sarasota County, Florida, known as the Palmer Ranch. In 1978, he borrowed $1,500,000 from Ellis Sarasota Bank & Trust Company and issued a…