Aurora Group, Ltd. v. Department of Revenue

DANIEL S. PEARSON, Judge.

This case involves the ad valorem taxation of a $2,500,000 promissory note executed by The Aurora Group, Ltd. (Aurora) secured by a mortgage of Aurora's 99-year leasehold interest in certain real property. At Aurora’s request, the Department of Revenue of the State of Florida issued a Declaratory Statement concerning the appropriate tax to be imposed on the note. To Aurora’s dismay, the Department ruled *1133that the note was subject to the annual tax of one mill on the dollar of the “just valuation” imposed by Section 199.032(1), Florida Statutes (1983), rather than, as…