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QUESTION: Does Ch. 201, F.S., require that documentary stamps be affixed to the $1,200,000 Public Improvement Revenue Bonds, Series 1974, Anticipation Notes of the City of Pinellas Park issued pursuant to a lending agreement under s. 215.431, F.S.?

SUMMARY: Documentary stamp taxes are required upon documents within the taxing purview of Ch. 201, F.S., even though one of the parties is a municipality. The nonexempt or nonimmune party thereto is liable for the purchase and affixation of such documentary stamps, since Ch. 201 places the burden of payment upon both parties to the document. Only in…