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Ms. Katie D. Tucker Executive Director Department of Revenue 102 Carlton Building Tallahassee, Florida 32399-0100

Dear Ms. Tucker:

This is in response to your request for my opinion on substantially the following questions:

1. Are the rents charged by port authorities, hospital authorities, and housing authorities subject to sales tax under Ch. 212, F.S., following the repeal by s. 5, Ch. 86-166, Laws of Florida, of the sales tax exemptions enumerated in ss. 125.019,154.2331, 159.15, 159.31, 159.50, and 159.708, F.S.?

2. If such rents are already pledged on July 1, 1987, to defray the cost of…