Choctawhatchee Electric Cooperative, Inc. v. Green

WIGGINTON, Chief Judge.

The sole question presented by this appeal is whether appellant, a private Florida corporation, is liable for payment of a documentary stamp tax on promissory notes executed by it in this state, which were thereafter delivered to and held by the United States of America as evidence of a loan. The notes are secured by a duly executed mortgage in favor of the United States and recorded in the public records of Walton County. From an adverse decree the protesting taxpayer has appealed.

Appellant premises its right to reversal upon the theory that the tax in question is one…