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Dear Ms. Parrish:

You ask substantially the following question:

May an educational institution receive an ad valorem taxation exemption pursuant to section 196.198, Florida Statutes, on improved real property which is partially leased at market rate to non-exempt commercial parties whose use is unrelated to educational purposes?

You state that a for-profit educational institution owns a parcel of land improved with a ten-story building.1 The first two floors are leased at the market rate to various commercial parties whose activities are unrelated to education. The remaining eight floors are…