Atheists of Florida, Inc. v. State, Department of Revenue

This is an appeal from a final administrative order denying a consumer certificate of a *443sales tax exemption to the Atheists of Florida, Inc. (“Atheists”) pursuant to section 212.08(7), Florida Statutes (1993) after an administrative hearing. At the hearing below, the Atheists maintained that its organization was entitled to a consumer’s certificate of exemption based upon the criteria set forth in section 212.08(7). Alternatively, the organization argued that the Department of Revenue’s (“Department”) implementation of section 212.08(7) is violative of its constitutional right to equal…