Rederi v. State, Department of Revenue

HENDRY, Chief Judge.

This is a petition for certiorari seeking review of a final order of the Department of Revenue of the State of Florida, as approved by the Governor and the State Cabinet, which upheld a use tax assessment against the petitioner.

Petitioner is a Norwegian corporation which operates three cruise vessels out of the Port of Miami. At the port, petitioner leases various passenger boarding facilities and has a holding area for the ship’s supplies. Petitioner has considered itself exempt from sales tax on items purchased from vendors and delivered to its port facilities for use as…