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Dear Ms. Faux:

You ask substantially the following question: Is a parking garage owned by the State of Florida but leased to a municipality that has sublet spaces to private individuals subject to ad valorem taxation?

It appears that you are inquiring about the taxability of the property itself. Florida follows the general rule that the state is immune from taxation and taxes may not be imposed upon the agencies or instrumentalities of the state unless they are specifically made subject to taxation.1 In Dickinson v. City of Tallahassee,2 the Supreme Court of Florida addressed the ability of a…