How did Florida tax a multistate refinancing involving assigned mortgages, an out-of-state $125 million note, a $100 Florida recovery cap, and consolidated renewal documents?

Plain-English summary

Most steps in the multistate refinancing produced no additional Florida documentary stamp or nonrecurring intangible tax. The Department accepted the requester's statutory and regulatory analysis for the described sequence.

The assignment of the original note and mortgage to the new lender was exempt. The new $125 million note, consolidated note, and replacement notes were made, executed, and delivered outside Florida and were not taxed merely because of those out-of-state transactions.

The second mortgage was recorded in Florida but limited principal recovery against the Florida property to $100. Florida therefore imposed only $0.35 of documentary stamp tax and $0.20 of nonrecurring intangible tax on that mortgage.

The consolidation-and-splitting agreement itself was not a taxable payment obligation or lien. The consolidated mortgage combined and restated the existing mortgages without increasing the relevant principal balances or the maximum amount recoverable against the Florida property, so it qualified for the stated renewal and refinancing exemptions and owed no additional tax.

What this means for you

The ruling treated each document and step separately. Location of execution and delivery, the purpose of an assignment, the amount recoverable from Florida property, prior tax payment, unchanged obligors, and whether consolidation enlarged principal all mattered.

Common questions

Q: Was the assignment of the original note and mortgage taxed?
A: No. The new lender purchased and became holder of the note and mortgage, and prior nonrecurring tax had been paid.

Q: Was the out-of-state $125 million second note taxed?
A: No. It was made, executed, and delivered outside Florida.

Q: Why did the recorded second mortgage owe only 55 cents total?
A: Recovery against the Florida property was limited to $100, producing $0.35 documentary stamp tax and $0.20 nonrecurring intangible tax.

Q: Were the consolidation agreement and replacement notes taxed?
A: No under the stated facts.

Q: Why was the consolidated mortgage exempt?
A: It did not add an obligor, increase the underlying principal balances, or increase the maximum principal recoverable against the Florida property beyond the amounts already secured and taxed.

Citations and references

• Fla. Stat. § 201.08(1) — documentary stamp tax on notes and recorded mortgages
• Fla. Stat. § 201.09(1) — renewal exemption
• Fla. Stat. § 199.133(1), (2) — nonrecurring intangible tax
• Fla. Stat. § 199.145(2), (4)(a) — assignments and refinancings
• Fla. Admin. Code rr. 12B-4.053(32)(b), (35), 12B-4.054(1), (6) — multistate mortgages, out-of-state notes, renewals, and assignments
• Fla. Stat. § 213.22 — Technical Assistance Advisements

Source

• Landing page: Florida Tax Law Library
• Advisement: TAA 95M-008

Original ruling text

Dec 18, 1995

Re: Technical Assistance Advisement No. 95(M)-008
Documentary Stamp Tax; Out of State Notes; Assignment of
Note and Mortgage; Renewal Note; Consolidated Note and
Mortgage; Splitting of Notes; Restricting Recoverability
Under a Mortgage:
Intangible Tax; Assignment of Note and Mortgage; Renewal
Mortgage; Consolidated Mortgage; Restricting Recoverability
Under the Mortgage;
XXX (Borrower)
XXX (the Initial Lender)
XXX (First Assignee)
XXX (the Second Assignee)
XXX (the "Interim Lender")
XXX (the "New Lender")

Dear :

You have petitioned for a Technical Assistance Advisement
pursuant to s. 213.22, F.S., and Rule 12-11.003, F.A.C.

Issue

Whether the assignment of an existing note and mortgage to
a new lender, the execution of a refinancing note and mortgage
in favor of the new lender, and the cross-collateralization
provisions of the mortgages are subject to documentary stamp tax
under s. 201.08, F.S., and intangible tax under s. 199.145, F.S.

Facts

Your client, the Borrower, has entered into a refinancing
transaction with respect to real and personal property owned by
the Borrower that is located both inside and outside the State
of Florida. The property located in Florida is referred to in
your letter as the "Florida Property", and the property located
outside Florida, as same may be added to, released or otherwise
changed from time to time, is referred to in your letter as the

"Out-of-State Property". The following is a chronology of
events that preceded the refinancing transaction:

1. The Borrower previously executed a Promissory Note
   dated June 12, 1992, in the original principal amount
   of One Hundred Fifty-Five Million and No/100 Dollars
   ($155,000,000.00) (the "Original Note") to the order
   of the Initial Lender.
2. The Original Note was secured by a First Mortgage,
   Security Agreement, Fixture Filing Statement,
   Assignment of Leases and Rents and Financing
   Statement, executed by the Borrower in favor of
   Initial Lender, dated as of June 1, 1992, recorded on
   June 15, 1992, in Official Records of a Florida County
   (the "Original Mortgage"). The Original Mortgage
   encumbers only the Florida Property.
3. The Original Note was also secured by mortgages (the
   "Out of State Mortgages") encumbering property located
   outside the State of Florida, each recorded in the
   state where each such property was located.
4. Non-recurring intangible personal property tax was
   properly paid upon the recording of the original
   Mortgage, prorated based upon the ratio of value of
   the Florida Property to the total value of the Florida
   Property and the property located outside the State of
   Florida (i.e., the Florida Property comprised 45.37%
   of the total collateral securing repayment of the
   Original Note). Documentary stamps were properly paid
   on the recording of the original Mortgage, based on
   the full face amount of the Original Note.
5. The Original Note and the Original Mortgage were
   assigned by Initial Lender to the First Assignee,
   pursuant to that certain Assignment of First Mortgage,
   Security Agreement, Fixture Filing Statement and
   Assignment of Rents and Leases, dated as of June 1,
   1992, recorded on June 15, 1992, in Official Records
   Book of a Florida County.
6. The Original Note and the original Mortgage were
   further assigned by the First Assignee to the Second
   Assignee, pursuant to an Assignment of First Mortgage,
   Security Agreement, Fixture Filing Statement and

Assignment of Rents and Leases and Financing
Statement, dated September 12, 1994, and recorded on
September 19, 1994, in Official Records Book of a
Florida County.

7. The Original Mortgage was modified pursuant to that
   certain Modification of First Mortgage, Security
   Agreement, Fixture Filing Statement, Assignment of
   Leases and Rents and Financing Statement dated
   September 12, 1994 (the "Initial Modification"), and
   recorded on September 19, 1994, in Official Records
   Book of a Florida County. The Initial Modification
   was exempt from documentary stamp tax and intangible
   tax, pursuant to Rule 12B-4.054(1), F.A.C., and s.
   199.145(4), F.S., because it satisfied all
   requirements of a renewal note and mortgage.
8. The Original Note and the Original Mortgage, as
   modified by the Initial Modification, were further
   assigned by the Second Assignee to the Interim Lender,
   pursuant to that certain Assignment of First Mortgage,
   Security Agreement, Fixture Filing Statement and
   Assignment of Rents and Leases, dated September 12,
   1994, and recorded on September 19, 1994, in Official
   Records Book of a Florida County.

For purposes of your request for a technical assistance
advisement, the Department assumes that documentary stamp taxes
and intangible taxes were properly affixed to the Original
Mortgage at the time of recording, and that the Initial
Modification was exempt from taxation because it satisfied all
requirements of a renewal note and mortgage.

II. Refinancing Transaction

The Borrower has entered into a refinancing transaction
whereby it has renewed the Original Note and borrowed additional
funds, all of which were thereafter consolidated and secured by
the Florida Property and by the Out of State Property. At the
time of recordation of the Second Mortgage, as defined below,
and the Consolidated Mortgage the value of the Florida Property
was not more than 45.37% of the total value of all collateral
(the Florida Property and the Out-of-State-Property).

In order to effectuate the refinancing transaction, the
following steps were taken in the order indicated:

1. First, the Interim Lender assigned the original
   Mortgage, as modified by the Initial Modification, and
   the Original Note to the New Lender by Assignment of
   Note and Mortgage (the "Assignment"). The Assignment
   was recorded on July 6, 1995 in Official Records of a
   Florida County.
2. Second, the Borrower made, executed and delivered to
   the New Lender an additional promissory note in the
   face amount of $125,000,000 (the "Second Note"). The
   Second Note was made, executed and delivered by the
   Borrower to the New Lender outside the State of
   Florida, and such out-of-state execution and delivery
   was evidenced in accordance with the provisions of
   Rule 12B-4.053(35), F.A.C.
3. Third, the Borrower made, executed and delivered to
   the New Lender a $125,000,000 Blanket Mortgage (the
   "Second Mortgage") . The Second Mortgage was recorded
   on July 6, 1995, in Official Records Book of a Florida
   County. The Second Mortgage encumbers the Florida
   Property and the Out of State Property. The Second
   Mortgage secures repayment of the Second Note, and all
   modifications, extensions, renewals, supplements, and
   substitutions therefor; provided, however, that with
   respect to the Florida Property only, recovery under
   the Second Mortgage on account of the principal
   balance of the Second Note is limited to the maximum
   amount of $100.00, together with accrued interest
   thereon, and advances for taxes, legal fees and costs
   of enforcement of the Second Mortgage.
4. Fourth, the Borrower made, executed and delivered to
   the New Lender a Consolidation and Splitting Agreement
   (the "Consolidation and Splitting Agreement"). The
   Consolidation and Splitting Agreement was recorded on
   July 6, 1995, in Official Records of a Florida County.
   The Consolidation and Splitting Agreement was made,
   executed and delivered outside the State of Florida,
   and such out-of-state execution and delivery was

evidenced in accordance with the provisions of Rule
12B-4.053(35), F.A.C. The Consolidation and Splitting
Agreement provided for the Borrower to execute and
deliver to the New Lender outside the State of
Florida:
(i)

a Consolidated Demand Renewal Note (the
"Consolidated Note"),

(ii)

two Restated Global Fixed Rate Notes, one
Restated Global Floating Rate Note, and one
Regulation S Restricted Global Floating Rate
Note (collectively, the "Notes"), and

(iii) a First Mortgage, Security Agreement,
Assignment of Leases and Rents and Fixture
Filing (the "Consolidated Mortgage").

5. Fifth, pursuant to the Consolidation and Splitting
   Agreement, the Borrower made, executed and delivered
   to the New Lender the Consolidated Note and the Notes.
   The Consolidated Note and the Notes were all made,
   executed and delivered by the Borrower to the New
   Lender outside the State of Florida, and such out-ofstate execution and delivery was evidenced in
   accordance with the provisions of Rule 12B4.053(35),F.A.C. The Consolidated Note was a renewal,
   consolidation and restatement of the Original Note and
   the Second Note, without enlargement of the principal
   balance of either of such notes. The Notes were in
   renewal of and substitution for the Consolidated Note,
   without enlargement of the principal balance of the
   Consolidated Note.
6. Sixth, pursuant to the Consolidation and Splitting
   Agreement, the Borrower made, executed and delivered
   to New Lender, the Consolidated Mortgage. The
   Consolidated Mortgage was recorded on July 6, 1995, in
   Official Records of a Florida County. The
   Consolidated Mortgage consolidated the Original
   Mortgage and the Second Mortgage, and amended and
   restated them in their entirety. The Consolidated
   Mortgage secures the Notes, and all modifications,
   extensions, renewals, supplements and substitutions
   therefor; provided, however, that with respect to the
   Florida Property only, recovery under the Consolidated

Mortgage on account of the principal balance due under
the Notes is limited to the maximum amount of
$155,000,100 (which is the sum of the maximum
principal amounts recoverable under the two mortgages
being consolidated), together with (i) interest on
such $155,000,100 amount; (ii) the prepayment penalty,
if any, payable in respect of such $155,000,100
amount; (ii) a gross up for any portion of the
interest payable on account of such $155,000,100
amount which is required to be withheld on payments to
non-resident aliens pursuant to the Internal Revenue
Code of 1986 (so that non-resident alien taxpayers
will receive the same net interest payments set out in
the Notes after taxes are withheld from the source);
and (iv) advances for taxes, insurance, attorneys'
fees and costs incurred in enforcing the Consolidated
Mortgage. The Consolidated Mortgage encumbers only
the Florida Property (and not the Out of State
Property). The Out of State Property is encumbered by
separate mortgages, all securing the Notes (to the
full extent of the Notes), which have been recorded in
the respective states in which the Out of State
Property is located.

III. Analysis And Rulings Requested

You submit that the proper treatment of each step of the
refinancing transaction described above for State of Florida
documentary stamp tax and intangible tax purposes is subject to
the analysis set forth by you below. Also set forth below are
the rulings requested by you from the Department of Revenue with
respect to each step of the refinancing transaction.

1. Consequences of Assignment of Original Note and
   Original Mortgage by the Interim Lender to the New
   Lender.

(a) Documentary Stamp Tax Analysis.

Rule 12B-4.054(6), F.A.C., provides, in part, as follows:

An assignment of a mortgage by a lender (mortgagee or owner
of the asset) to a new lender who has purchased the note
and mortgage and becomes the holder of the note and
mortgage is not taxable.

Accordingly, in your opinion, no documentary stamp tax is
due on the Assignment.

You request a ruling that no documentary stamp tax is due
on the Assignment.

(b) Non-recurring Intangible Tax Analysis:

Section 199.145(2), Florida Statutes, provides as follows:

No additional non-recurring tax shall be due upon the
assignment by the obligee of a note, bond or other
obligation for the payment of money upon which a nonrecurring intangible tax has previously been paid.

Accordingly, in your opinion, no additional non-recurring
intangible tax is due on the Assignment.

You request a ruling that no non-recurring intangible tax
is due on the Assignment.

2. Consequences of Execution and Delivery of the Second
   Note.

(a) Documentary Stamp Tax Analysis.

Rule 12B-4.053(35), F.A.C., provides, in part, as follows:

Promissory notes, nonnegotiable notes, and written
obligations to pay money (hereinafter, called notes), made,
executed, and delivered to a Florida lender in another state are
not subject to Florida documentary stamp tax.

Accordingly, in your opinion, no documentary stamp taxes
are due in connection with the making, execution and delivery of
the Second Note by the Borrower to the New Lender outside the

State of Florida.

You request a ruling that the making, execution and
delivery of the Second Note by the Borrower to the New Lender,
outside the State of Florida are exempt from documentary stamp
tax.

(b) Non-Recurring Intangible Tax Analysis.

Section 199.133(2), Florida Statutes, provides, in part, as
follows:

The non-recurring tax shall apply to a note, bond or other
obligation for payment of money only to the extent it is secured
by mortgage, deed of trust, or other lien upon real property
situated in this state.

In your opinion, the making, execution and delivery of the
Second Note outside the State of Florida, standing alone, does
not give rise to non-recurring intangible taxes, pursuant to the
express provisions of Section 199.133(2), Florida Statutes.

You request a ruling that pursuant to s. 199.133(2), F.S.,
no non-recurring intangible taxes are due upon the making,
execution and delivery of the Second Note outside the State of
Florida.

3. Consequences of Execution and Recording of the Second
   Mortgage.

a. Documentary Stamp Tax Analysis

Section 201.08(1), F.S., provides for the documentary stamp
tax to be paid on mortgages recorded in the State of Florida
(regardless of where executed), at the rate of $.35 on each $100
of the indebtedness or obligation evidenced thereby.

However, Rule 12B-4.053(32)(b), F.A.C., provides, in part,
as follows:

When a note is made in another state and is secured by a

multi-state mortgage recorded in Florida which describes
and pledges the Florida property and the out-of-state
property, tax will be due on the mortgage when filed or
recorded in Florida based upon the percentage of
indebtedness which the value of the mortgaged property in
Florida bears to the total value of all the mortgaged
property. However, where the mortgage limits recovery to
less than the amount of the indebtedness secured, the tax
is due on the amount to which recovery is limited.

In your opinion, because the recovery under the Second
Mortgage is limited, as to the Florida Property, to $100,
together with accrued interest thereon, and advances for taxes,
legal fees and costs of enforcement of the Second Mortgage, the
amount of documentary stamp tax due upon the recording of the
Second Mortgage should be based on the $100 principal amount to
which recovery is limited pursuant to the terms of the Second
Mortgage.

You request a ruling that the documentary stamp tax due
upon the recording of the Second Mortgage is $.35, based on the
$100 principal amount to which recovery is limited pursuant to
the terms of the Second Mortgage.

b. Non-recurring Intangible Tax Analysis

Section 199.133(1), F.S., provides for a nonrecurring tax
of 2 mills on each dollar of just valuation of all notes, bonds
and other obligations for payment of money which are secured by
mortgage, deed of trust, or other lien upon real property
situated in Florida. Section 199.133(2), F.S., provides, in
part, as follows:

The non-recurring tax shall apply to a note, bond, or other
obligation for payment of money only to the extent it is secured
by mortgage, deed of trust, or other lien upon real property
situated in this state.

In your opinion, because the Second Mortgage secures
payment of the maximum principal amount of $100 due under the
Second Note, the nonrecurring intangible tax due upon the

recording of the Second Mortgage should be based on the $100
principal amount of the Second Note to which recovery is
limited.

You request a ruling that the non-recurring intangible tax
due upon the recording of the Second Mortgage is $.20, based on
the $100 principal amount of the Second Note to which recovery
is limited.

4. Consequences of Execution and Delivery of
   Consolidation and Splitting Agreement.

(a) Documentary Stamp Tax Analysis.

Section 201.08(1), F.S., provides for documentary stamp tax
to be payable on (i) promissory notes, non-negotiable notes,
written obligations to pay money, or other compensation made,
executed, delivered, sold, transferred or assigned in the State
of Florida, and for each renewal of same, and (ii) mortgages,
trust deeds, security agreements, or other evidences of
indebtedness filed or recorded in Florida, and for each renewal
of same.

The Consolidation and Splitting Agreement does not fall
within any of the categories described above, but rather
evidences the consolidation and splitting of various notes and
mortgages, the consequences of which are addressed elsewhere in
this request for a technical assistance advisement.
Accordingly, in your opinion, no documentary stamp tax is due on
the Consolidation and Splitting Agreement.

You request a ruling that no documentary stamp tax is due
in connection with the making, execution, delivery or recording
of the Consolidation Agreement.

(b) Non-Recurring Intangible Tax Analysis. Section
199.133(1), F.S., provides for the non-recurring intangible
tax to be paid on notes, bonds and other obligation for the
payment of money which are secured by mortgage, deed of
trust, or other lien upon real property situated in
Florida.

The Consolidation and Splitting Agreement does not fall
within any of the categories described above, but rather
evidences the consolidation and splitting of various notes and
mortgages, the consequences of which are addressed elsewhere in
this request for a technical assistance advisement.
Accordingly, in your opinion, no non-recurring intangible tax is
due on the Consolidation and Splitting Agreement.

You request a ruling that no non-recurring intangible tax
is due in connection with the making, execution, delivery or
recording of the Consolidation Agreement.

5. Consequences of Execution and Delivery of Consolidated
   Note and Notes.

(a) Documentary Stamp Tax Analysis

Rule 12B-4.053(35), F.A.C., provides, in part, as follows:

Promissory notes, nonnegotiable notes, and written
obligations to pay money (hereinafter, called notes), made,
executed, and delivered to a Florida lender in another
state are not subject to Florida documentary stamp tax.

In your opinion, because the Consolidated Note and the
Notes were made, executed and delivered by the Borrower to the
New Lender outside of the State of Florida, documentary stamp
tax is not due on the making, execution or delivery of the
Consolidated Note and the Notes.

You request a ruling that the making, execution and
delivery of the Consolidated Note and the Notes by the Borrower
to the New Lender outside the State of Florida are exempt from
documentary stamp tax.

(b) Non-Recurring Intangible Tax Analysis.

Section 199.133(2), F.S., provides, in part, as follows:

The nonrecurring tax shall apply to a note, bond or other

obligation for payment of money only to the extent it is
secured by mortgage, deed of trust, or other lien upon real
property situated in this state.

The making, execution and delivery of the Consolidated Note
and the Notes outside the State of Florida, standing alone, does
not give rise to non-recurring intangible taxes, pursuant to the
express provisions of s. 199.133(2), F.S.

You request a ruling that pursuant to s. 199.133(2), F.S.,
no non-recurring intangible taxes are due upon the making,
execution and delivery of the Consolidated Note and the Notes
outside the State of Florida.

6. Consequences of Execution, Delivery and Recording of
   the Consolidated Mortgage.

(a) Documentary Stamp Tax Analysis.

Section 201.09(1), F.S., provides for an exemption from the
State of Florida documentary stamp tax where a renewal
obligation satisfies the following criteria:

(i)

The renewal obligation is signed by the same
obligor without any additional obligors added;

(ii)

There is no increase in the principal balance;
and

(iii)

Documentary stamp taxes were paid upon the
initial obligation in the full amount due
thereon.

Rule 12B-4.054(1)(a), F.A.C., treats as an exempt renewal a
consolidation of two or more contractual obligations, without
enlargement of the existing principal balance.

Rule 12B-4.054(1)(c), F.A.C., treats as an exempt renewal
two or more notes which are substituted for an existing note,
without enlargement of the existing principal balance.

In your opinion, because the Borrower is the sole obligor
on the Original Mortgage, the Second Mortgage and the

Consolidated Mortgage, the first requirement of s. 201.09, F.S.,
is satisfied.

The outstanding principal balances of the Original Note and
the Second Note were not increased by the Consolidated Note, and
the outstanding principal balance of the Consolidated Note was
not increased by the Notes. Similarly, the maximum principal
amount recoverable against the Florida Property on account of
the Original Mortgage and the Second Mortgage was not increased
on account of the Consolidated Mortgage (i.e., recovery against
the Florida Property under the Consolidated Mortgage continues
to be limited to $155,000,100, the sum of the principal amounts
recoverable under the Original Mortgage and the Second
Mortgage). Accordingly, in your opinion, the second requirement
is satisfied because there has been no increase in the
outstanding principal balances of the Notes secured by the
Original Mortgage and the Second Mortgage, (i.e., $280,000,000),
and there has been no increase in the maximum principal amount
recoverable against the Florida Property (i.e., $155,000,100).

In your opinion, because documentary stamp taxes were paid
on the Original Mortgage and on the Second Mortgage in the full
amount due thereon (in the case of the Original Mortgage, at the
rate of 35 cents per $100 of indebtedness, and in the case of
the Second Mortgage, based on the principal amount to which
recovery was limited), no additional documentary stamp tax is
due upon the execution, delivery or recording of the Second
Mortgage. Thus, the third requirement is satisfied.

You request a ruling that no documentary stamp tax is due
upon the execution, delivery or recording of the Consolidated
Mortgage.

(b) Intangible Tax Analysis.

Section 199.145(4)(a), F.S., provides as follows:

Where a note, bond or other obligation upon which a nonrecurring tax has previously been paid is refinanced with
the original obligee or its assignee:

(a) No additional non-recurring tax is due if the principal
balance of the new obligation is less than or equal to the
unpaid principal balance of the original obligation, plus
accrued but unpaid interest, as of the refinancing.

In your opinion, because the outstanding principal balance
of the Consolidated Note is not greater than the combined
principal balances of the Original Note and the Second Note, and
because the recovery amount under the Consolidated Mortgage has
not been increased beyond the sum of the recovery amounts under
the original Mortgage and the Second Mortgage, the execution,
delivery and recovery of the Consolidated Mortgage is exempt
from any additional non-recurring intangible tax.

You request a ruling that the execution, delivery and
recording of the Consolidated Mortgage is exempt from any
additional non-recurring intangible tax.

Discussion and Law

Your Florida Statutes and Florida Administrative Rules
analyses are correct and appropriate for the rulings requested
as to whether the documentary stamp tax and intangible tax are
due on the transactions described.

Department's Position

Therefore, the assignment of the Original note and Original
mortgage by the Interim Lender to the New Lender is exempt from
both the documentary stamp tax and intangible tax under s.
201.09, F.S., and s. 199.145, F.S. In addition, the execution,
delivery of the Second note by the Borrower to the New Lender
out of Florida is exempt from the documentary stamp tax and
intangible tax under s. 201.09, F.S., and s. 199.145, F.S.
Further, the recordation of the Second Mortgage is taxable for
only the $.35 documentary stamp tax and $.20 intangible tax
based on the $100 recovery amount set forth in the mortgage. As
to the execution, delivery, or recordation of the Consolidation
Agreement and Splitting Agreement, the Consolidated Note and the
Notes, neither the documentary stamp tax nor the intangible tax
is due. Also, the recordation of the Consolidated Mortgage is

not taxable for either the documentary stamp tax or the
intangible tax.

This response constitutes a Technical Assistance Advisement
under s. 213.22, F.S., which is binding on the Department only
under the facts and circumstances described in the request for
this advice as specified in s. 213.22, F.S. Our response is
predicated on those facts and the specific situation summarized
above. You are advised that subsequent statutory or
administrative rule changes or judicial interpretations of the
statutes or rules upon which this advice is based may subject
similar future transactions to a different treatment than
expressed in this response.

You are further advised that this response and your request
are public records under Chapter 119, F.S., which are subject to
disclosure to the public under the conditions of s. 213.22, F.S.
Your name, address, and any other details which might lead to
identification of the taxpayer must be deleted by the Department
before disclosure. In an effort to protect the confidentiality
of such information, we request you notify the undersigned in
writing within 15 days of any deletions you wish made to the
request or the response.

Sincerely,

James E. Silvey
Tax Law Specialist
Tax Policy and Dispute Resolution
Office of General Counsel

JES/mh