Allstate Enterprises, Inc. v. State, Department of Revenue

OWEN, WILLIAM C., Jr. (Retired), Associate Judge.

Allstate Enterprises, Inc. (“Appellant”) was assessed by the Department of Revenue for Florida intangible tax on certain promissory notes which it did not own. Asserting that it is not considered good business practice to pay taxes on property owned by others, Appellant seeks review of the Department’s final order.

The question here is whether Appellant must file an intangible tax return pursuant to Section 199.052(1), Florida Statutes *850(1977),1 as to the notes which (so the State claims) have a business situs in the State of Florida by virtue of…