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Mr. Randy Miller Executive Director Department of Revenue Carlton Building Tallahassee, Florida 32301

Dear Mr. Miller:

You have requested my opinion on whether the Department of Revenue is authorized to assign its rights under a recorded tax warrant in the following situations:

1. UPON OPENING A BUSINESS, A TAXPAYER HAS POSTED A BOND WITH THE DEPARTMENT OF REVENUE PURSUANT TO CHAPTER 212, F.S. WHILE IN BUSINESS, A TAX LIABILITY ARISES BUT IS NOT PAID. SUBSEQUENTLY A TAX WARRANT IS ISSUED BY THE DEPARTMENT AND IS RECORDED. THE BONDING COMPANY PAYS OFF THE LIABILITY AS REQUIRED UNDER THE BOND. THE…