How did Florida tax mandatory beach packages, optional golf packages, and condominium registrations sold with resort rentals?

Subject

Components of Package Resort Accommodations

Plain-English summary

Florida taxed the full lump-sum price of the condominium rental and mandatory beach package as transient rent. Every guest buying that resort package received the room plus beach chairs, umbrellas, and other beach amenities, with no option to refuse the beach component. The manager also owed tax when it bought the beach package from the beach-service company because that service was not directly resold as a separate guest charge.

Internal distribution of the resort-package income did not create additional taxable beach-service purchases. Amounts shared with the homeowners' association or unit owner, and profit retained by the manager, were not payments for beach services; only the amount paid to the beach-service company was taxable at that purchase level.

The optional golf package received different treatment because the manager sold it separately and itemized it on the guest's bill. Golf admissions could not be bought tax-free for resale. The golf club collected tax from the manager, and the manager collected tax from a guest when reselling above its cost, taking credit for the tax previously paid.

As the owners' rental agent, the manager could use collective-registration procedures, but it still had to provide information and pay the registration fee for each condominium unit. Registering only each condominium complex was not sufficient.

What this means for you

For Florida resort packages, whether an amenity is mandatory, optional, separately itemized, and withheld when unpaid can change its treatment. Property managers should also distinguish collective filing mechanics from the requirement to identify and register each underlying rental property.

Common questions

Q: Could the manager tax only the internally assigned beach-package amount charged to the guest? No. The full mandatory room-and-beach package was taxable transient rent.

Q: Were distributions to the condominium association and unit owner taxable beach-service purchases? No. The ruling treated them as allocations of package income, not purchases of beach services.

Q: How did the golf-package credit work? When the manager resold the admission above cost, it collected tax on the guest price and credited the tax paid to the golf course. The ruling noted that a resale at or below cost produced neither additional tax nor a credit.

Q: Could one registration cover an entire condominium complex? No. The agent could register collectively by county, but the required information and fee applied to each unit.

Citations and references

• Fla. Stat. § 212.03; Fla. Admin. Code r. 12A-1.061(3)-(4) — transient rentals, mandatory guest charges, and owner purchases
• Fla. Stat. §§ 212.02(1), 212.04(1)(c) — golf admissions and tax credit on resale above cost
• Fla. Stat. § 212.18(3); Fla. Admin. Code rr. 12A-1.060(1)(c), 12A-1.061(7) — agent registration of transient accommodations
• Fla. Stat. § 213.22 — Technical Assistance Advisements

Source

• Landing page: Florida Tax Law Library
• Advisement: TAA 98A-064

Original ruling text

SUMMARY

The taxpayer is a property management company providing
transient rental accommodations owned by others to the
traveling public. The taxpayer offers an arrangement in
which a guest rents accommodations with a beach package for
a lump sum charge. For a single lump sum charge, the beach
package entitles the guest the right to occupy transient
accommodations, as well as the right to use beach chairs,
beach umbrellas, and other beach side amenities. The
taxpayer purchases the beach package from a beach service
company. Tax is not due, however, on distribution of the
income from the beach package to the homeowners'
association or the unit owner.

The taxpayer also offers a golf package in addition to the
transient rentals. Golf packages are purchased separately
by the guest, and are separately itemized on the invoice to
the guest. Tax is due on the taxpayer's purchase of the
golf package from the golf club. Tax is also due on the
charge to the guest by the taxpayer, however, assuming the
golf package is resold for more than the purchase price,
the taxpayer should take credit against tax due for tax
paid to the golf club.

As the owners' agent, the taxpayer must register each unit
for sales tax, not each condominium complex location.

Aug 21, 1998

Re: Technical Assistance Advisement 98A-064
Sales and Use Tax - Components of Package Resort
Accommodations
Sections: 212.02, 212.03, 212.04, 212.18(3), F.S.
Rules: 12A-1.060, 12A-1.061, F.A.C.
Petitioner: XXX (herein "Taxpayer")
FEI: XX

Dear :

This letter is a response to your petition dated April 21, 1998,
for the Department's issuance of a Technical Assistance
Advisement ("TAA") concerning the above referenced party and
matter. Your petition has been carefully examined and the
Department finds it to be in compliance with the requisite
criteria set forth in Chapter 12-11, F.A.C. This response to
your request constitutes a TAA and is issued to you under the
authority of s. 213.22, F.S.

FACTS

The Taxpayer is responsible for the marketing of condominium
units owned by individuals. Resort packages are offered for a
lump sum price. The Taxpayer was issued a Letter of Technical
Advice dated January 13, 1998, regarding the taxability of the
resort or beach packages.

From the Letter of Technical Advice, quoting your request for
advice:

... By way of example the unit will be marketed using a
fixed dollar per night rate which includes the right to the
room as well as the right to a beach package which might
include the use of oceanside facilities and equipment. The
tenant has no option as to whether they pay or don't pay
for the beach side accommodation if they have taken this
all inclusive package.

For example, the charge might be $125 per night which
includes the room and the right to the beach package. The
beach package is not provided directly by [Taxpayer].
[Taxpayer] has been collecting the tax on the full $125 and
has been remitting it net of collection allowance to the
Department....

From your request for a Technical Assistance Advisement:

... Further inquiry relates to the payment of amounts
collected from the customer related to the provision of

beach packages by the taxpayer as part of the resort
package. Of the total amount collected from the tenant for
the "resort package," a portion is attributable (without
separate statement to the [tenants]) within the internal
cost accounting of [Taxpayer] to be allocated or
distributed in the following fashion:

1. A portion will go to the homeowner's association of the
   condominium in which the rental occurs for purposes of
   authorizing [Taxpayer] to engage in the activities under
   the agency rental arrangements with the owners of the
   condominium, who are members of the homeowner's
   association.
2. [Taxpayer] will retain a portion for its own purposes.
3. The owner of the unit will receive a portion.
4. A portion is paid directly to the beach service for the
   services rendered by the beach service to the transient
   tenants.

The taxpayer also sells golf packages as part of the vacation
package to the guest. The charge for the golf package is
separately stated on the bill to the guest, and taxed. The golf
course collects tax on its charge to the taxpayer for the golf
fees.

REQUESTED ADVISEMENT

1. The taxpayer requests a determination that only the
   amount paid to the beach rental service is subject to sales tax.
2. The taxpayer requests a determination relating to
   registration requirements for the taxpayer as an agent for
   owners of the condominium units which are leased to tenants. The
   taxpayer requests confirmation that its obligations under the
   registration requirement for sales tax purposes as a dealer
   would be satisfied if they would register each condominium
   complex location, rather than individual condominium units, and
   collect and remit taxes on behalf of the owners on the charges
   to the tenants.
3. The taxpayer requests a determination that the golf
   course is properly charging tax to the taxpayer on its purchase
   of the golf package, and that the taxpayer should take a credit

for the amount of tax paid to the golf course against tax due to
the Department.

Discussion, Analysis, and Conclusion of Law

Section 212.03, F.S., provides in pertinent part:

(1) It is hereby declared to be the legislative intent that
every person is exercising a taxable privilege who engages
in the business of renting, leasing, letting, or granting a
license to use any living quarters or sleeping or
housekeeping accommodations in, from, or a part of, or in
connection with any hotel, apartment house, roominghouse,
or tourist or trailer camp.... For the exercise of such
taxable privilege, a tax is hereby levied in an amount
equal to 6 percent of and on the total rental charged for
such living quarters or sleeping or housekeeping
accommodations by the person charging or collecting the
rental. Such tax shall apply to hotels, apartment houses,
roominghouses, or tourist or trailer camps whether or not
there is in connection with any of the same any dining
rooms, cafes, or other places where meals or lunches are
sold or served to guests.
(2) The tax provided for herein shall be in addition to the
total amount of the rental, shall be charged by the lessor
or person receiving the rent in and by said rental
arrangement to the lessee or person paying the rental, and
shall be due and payable at the time of the receipt of such
rental payment by the lessor or person, as defined in this
chapter, who receives said rental or payment....

Rule 12A-1.061, F.A.C., effective November 30, 1997, provides in
pertinent part:

(3) RENTAL CHARGES OR ROOM RATES.
(a) Rental charges or room rates for the use or possession,
or the right to the use or possession, of transient
accommodations are subject to tax, whether received in
cash, credits, property, goods, wares, merchandise,
services, or other things of value.

(b)1. Rental charges or room rates include any charge or
surcharge to guests or tenants for the use of items or
services that is required to be paid by the guest or tenant
as a condition of the use or possession, or the right to
the use or possession, of any transient accommodation. Such
charges or surcharges are included even when the charges to
the transient guest are:
a. separately itemized on a guest's or tenant's bill,
invoice, or other tangible evidence of sale; or
b. made by the owner or the owner's representative to the
guest or tenant for items or services provided by a third
party.

2. Rental charges or room rates do not include charges or
   surcharges to guests or tenants for the use of items or
   services for transient accommodations when:
   a. the charges or surcharges are separately itemized on a
   guest's or tenant's bill, invoice, or other tangible
   evidence of sale; and
   b. the items or services are withheld when a guest or
   tenant refuses to pay the charge or surcharge.
3. Rental charges or room rates include charges or
   surcharges for the use of items or services when all guests
   or tenants receive the use of such items or services. Such
   charges or surcharges are subject to tax even though the
   charges to an individual guest or tenant may be adjusted to
   waive the charge or surcharge or the charges are separately
   itemized on a guest's or tenant's bill, invoice, or other
   tangible evidence of sale. Any waiver of a charge or
   surcharge to an individual guest or tenant is considered an
   adjustment to the rental charges or room rates for
   transient accommodations.
   4.a. Example: A guest rents a room in a resort hotel that
   charges each guest a $5 resort fee to receive daily
   newspapers and use of its health club facilities. When a
   guest objects to the fee, the hotel will waive the fee for

that individual guest. All guests receive the newspaper and
may use the health club facilities, whether or not the
guest pays the fee. The $5 resort fee charged by the resort
hotel to its guests is included in the room rates subject
to tax. When the resort hotel waives the fee for an
individual guest, the waiver of the fee is considered an
adjustment to the room rate.
b. Example: A guest rents a beach cottage for three months.
The owner of the cottage requires the cottage to be cleaned
by Company X and separately itemizes the cleaning services
on the guest's bill. Because the charges for the cleaning
services provided by Company X are required to be paid as a
condition for the right to use the beach cottage, the
charges are included in the rental charges and are subject
to tax. The charges are subject to tax even though the
cleaning services are provided by a third party and the
charges are separately stated on the guest's bill.
c. Example: A guest rents a condominium unit from the unit
owner for two weeks. If a guest wants daily cleaning
services, the owner will arrange for these services, but
does not require the guest to purchase the additional
services. The unit owner separately itemizes the additional
maid services on the guest's bill. Because the additional
maid services are not a requirement for the right to use
the condominium unit and the guest does not receive the
services without payment for the services, the charges are
not included in the amount of taxable rental charges....

(4) PURCHASES BY OWNERS OR OWNERS' REPRESENTATIVES OF
TRANSIENT ACCOMMODATIONS.
(a) The purchase of beddings, furnishings, fixtures,
toiletries, consumables, taxable maid and cleaning
services, and similar items or other taxable services by
owners or owners' representatives of transient
accommodations is subject to tax, except as provided in
paragraphs (b) or (c). The purchase of these items and
services is not subject to the tourist development tax, as
provided in s. 125.0104, F.S., the tourist impact tax, as
provided in s. 125.0108, F.S., or the convention
development taxes, as provided in s. 212.0305, F.S.

(b) Owners or owners' representatives may purchase or lease
tangible personal property without paying tax only when the
taxable property is:

1. purchased exclusively for resale or re-rental as
   provided in Rule 12A-1.071(2), F.A.C.; and
2. charges to the guest or tenant for the purchased or
   leased property are not required under the provisions of
   this rule to be included in the taxable amount of rental
   charges or room rates. See Rule 12A-1.071(2), F.A.C.
   (c)1. Owners or owners' representatives that do not have a
   dealer's sales tax number ending in digits 92 or 93 are not
   permitted to purchase taxable services exempt from tax. See
   Rule 12A-1.0161, F.A.C. However, owners or owners'
   representatives may take a credit for tax paid to a dealer
   of taxable services on its sales and use tax return when:
   a. the charges or surcharges for the taxable service
   purchased for resale to the guest or tenant are separately
   stated on a guest's or tenant's bill, invoice, or other
   tangible evidence of sale;
   b. the applicable sales tax is collected from the guest or
   tenant on the separately stated charges for the taxable
   service (see Rules 12A-1.0091, 12A-1.0092, and 12A-1.0161,
   F.A.C.);
   c. the charges or surcharges to the guest or tenant are not
   required under the provisions of subsection (3) of this
   rule to be included in the taxable amount of rental charges
   or room rates; and
   d. tax was paid to the dealer for the taxable service.
3. Example: Company X is in the business of renting
   condominium units. As part of its rental charges, Company X
   provides weekly cleaning services to its tenants. If a
   tenant wants to purchase daily cleaning services, Company X
   will arrange with a third party cleaning company to provide

the cleaning services. Company X separately states the
charge for the daily cleaning services and the applicable
sales tax for the cleaning services on the tenant's
accommodation bill. Company X purchases all its cleaning
services from the third party cleaning company and must pay
the applicable sales tax to the cleaning company on its
total charges for cleaning services. However, Company X may
take a credit on its sales and use tax return for the tax
paid to the third party cleaning company on the charges for
daily cleaning services that are resold to its tenants,
whether the daily cleaning services are resold to the
tenant at the same or a higher price than that paid to the
third party cleaning company.

The taxpayer is a resort management company, managing the rental
of condominium units owned by individuals, providing transient
rentals. The taxpayer provides resort packages for a single
price, which includes the room rental and a beach package. The
beach package includes the use of gulf side facilities and
equipment. The total sale of the resort package is subject to
tax as a transient rental. The charge for the beach package is
not separately stated on the invoice to the guest, but is
included as part of the price of the accommodations.
Additionally, tax is due on the taxpayer's purchase of the beach
package from the beach service company, as such package is not
directly resold by Taxpayer to its guests.

The information provided with the request for the Letter of
Technical Advice assumed that the entire income from the beach
package portion of the sale of the resort package was paid to
the beach service company. The additional information provided
in the request for a Technical Assistance Advisement concerns
the taxpayer's internal accounting allocations of the income and
expenses of the beach package. As part of the taxpayer's
management agreement, the income from the beach package is
shared among the several entities involved in the rental of the
unit, rather than paid entirely to the beach service company. A
portion of the income is distributed to the homeowner's
association of the condominium in which the rental occurs; a
portion is distributed to the owner of the individual unit; the
taxpayer keeps a portion as its profit on selling the resort

package; and finally, the beach service company is paid for the
beach rental service package.

You are correct in your assertion that the payments to the
homeowners' association and the unit owner, and the retainage by
the taxpayer are not taxable items. The taxpayer is not
purchasing a beach package from either the homeowners'
association or the unit owner, but rather sharing the profit
from the income from the sale of the resort package. You are
correct in your assertion that only the amount paid by Taxpayer
to the beach service company is subject to tax.

Section 212.18(3)(a), F.S., provides in pertinent part:

Every person desiring to... lease, rent, or let or grant
licenses in living quarters or sleeping or housekeeping
accommodations in hotels, apartment houses, roominghouses,
or tourist or trailer camps that are subject to tax under
s. 212.03,... must file with the department an application
for a certificate of registration for each place of
business, showing the names of the persons who have
interests in such business and their residences, the
address of the business, and such other data as the
department may reasonably require.... The application must
be made to the department before the person, firm,
copartnership, or corporation may engage in such business,
and it must be accompanied by a registration fee of $5....
The department, upon receipt of such application, will
grant to the applicant a separate certificate of
registration for each place of business.... The certificate
is not assignable and is valid only for the person, firm,
copartnership, or corporation to which issued.... Except as
provided in this paragraph, no person shall engage... in
leasing, renting, or letting of or granting licenses in
living quarters or sleeping or housekeeping accommodations
in hotels, apartment houses, roominghouses, tourist or
trailer camps,... without first having obtained such a
certificate or after such certificate has been canceled; no
person shall receive any license from any authority within
the state to engage in any such business without first
having obtained such a certificate or after such

certificate has been canceled. The engaging... in leasing,
renting, or letting of or granting licenses in living
quarters or sleeping or housekeeping accommodations in
hotels, apartment houses, roominghouses, or tourist or
trailer camps that are taxable under this chapter,...
without such certificate first being obtained or after such
certificate has been canceled by the department, is
prohibited. The failure or refusal of any person, firm,
copartnership, or corporation to so qualify when required
hereunder is a misdemeanor of the first degree, punishable
as provided in s. 775.082 or s. 775.083, or subject to
injunctive proceedings as provided by law. Such failure or
refusal also subjects the offender to a $100 initial
registration fee in lieu of the $5 registration fee
authorized in this paragraph.

Rule 12A-1.061(7), F.A.C., effective November 30, 1997,
implements the above law, and provides in pertinent part:

(b)1. Transient accommodations, including timeshare units,
that are rented, leased, let, or for which a license to use
has been granted to others for periods [of] six months or
less may be collectively registered by an agent,
representative, or management company under the provisions
of Rule 12A-1.060(1)(c), F.A.C. (See Rule 12A-1.060,
F.A.C.)

Rule 12A-1.060(1)(c), F.A.C., also implements the above law, and
provides:

(c)1. Any agent, representative, or management company may
collectively register transient accommodations, as defined
in Rule 12A-1.061, F.A.C., including timeshare units, that
are rented, leased, let, or for which a license to use has
been granted to others for periods [of] six months or less
under the following conditions:
a. the agent, representative, or management company has
obtained a dealer's certificate of registration as
provided in subparagraph (a)1., above;

b. the agent, representative, or management company is
authorized by means of a written agreement with the
property owner to collect rental charges or room rates due
on any transient accommodations, as defined in Rule 12A1.061, F.A.C.; and

c. the written agreement contains the following provisions
acknowledged by the property owner:

I. the property owner is ultimately liable for any sales
tax due the State of Florida on rentals, leases, lets, or
licenses to use the owner's property; and

II. in the event that the State is unable to collect any
taxes, penalties, and interest due from the rental, lease,
let, or license to use the owner's property, a warrant for
such uncollected amount will be issued and will become a
lien against the owner's property until satisfied.

2. The agent, representative, or management company may
   collectively register properties described in subparagraph
   1., above, that are located in a single county by filing an
   Application for Collective Registration for Rental of
   Living or Sleeping Accommodations (Form DR-1C, incorporated
   by reference in Rule 12A-1.097, F.A.C.) for each county.

3. The agent or management company must provide the
   following information for each property, other than a timeshare unit, which is to be collectively registered:

a. property owner's name;

b. property owner's federal identification number (if
applicable);

c. property owner's mailing address;

d. location address of each property; and

e. an indication of whether the property is located within
a city's limits.

4. The agent or management company must provide the
following information for each time-share unit, which is to
be collectively registered:

a. designation of the time-share unit;

b. time-share unit's location address; and

c. an indication of whether the time-share unit is located
within a city's limits.

5. In lieu of completing Form DR-1C for each unregistered
   property or time-share unit, the information required for
   each property or time-share unit may be submitted to the
   Department in a schedule attached to the completed "Agent's
   Sales Tax Registration Information" section of Form DR-1C,
   containing the agent or management company's name, mailing
   address, federal identification number (if applicable), and
   sales tax registration number. The schedule must contain
   all the required information listed in subparagraph 2. or
   3., as applicable, so that the processing of the
   information may be accomplished by the Division of Tax
   Processing.

6. A $5 registration fee... must accompany the application
   for such property or time-share unit which is not currently
   registered with the Department. A Sales and Use Tax
   Certificate of Registration (Form DR-11) will be issued to
   the property owner for each property other than time-share
   units and mailed to the agent's address. For time-share
   units, a certificate of registration will be issued and
   mailed to the agent or management company. See Rule 12A1.061(16), F.A.C.

7. When any agent or management company which has
   registered any property with the Department under the
   provisions of subparagraphs 1. and 2., or 1. and 3., enters
   into additional written agreements with owners of
   properties or time-share units authorizing the licensed
   dealer to collect the rental, lease, or license payments as

agent for the property owner after filing the initial Form
DR-1C (or schedule) with the Department, the agent or
management company may file an additional Form DR-1C (or
schedule) to collectively register any additional such
property or time-share unit which is rented, leased, let,
or in which a license to use has been granted to others.
Each additional Form DR-1C (or schedule) must contain the
information required in subparagraph 2. or 3., as
applicable; the agent or management company's name, mailing
address, federal identification number (if applicable), and
sales tax registration number; and must be accompanied by a
$5 registration fee, except as provided in subparagraph
(1)(a)2. of this rule, for each property or each time-share
unit which is not currently registered with the Department.
(Emphasis Supplied)

The taxpayer endeavors to determine if, under registration
requirements of the taxpayer as agent for owners, each
condominium complex location, rather than each condominium unit,
may be registered.

Rule 12A-1.060(1)(c), F.A.C., provides that an agent may
collectively register transient accommodations. However,
subparagraph 3. provides that the agent must provide specific
information concerning each unit, and subparagraph 6. provides
that a $5 registration fee must accompany the application for
each unit registered. Therefore, it would be inappropriate for
the taxpayer to register each condominium complex location,
rather than each unit.

Section 212.04, F.S., provides in pertinent part:

(1)(a) It is hereby declared to be the legislative intent
that every person is exercising a taxable privilege who
sells or receives anything of value by way of admissions.

(b) For the exercise of such privilege, a tax is levied at
the rate of 6 percent of sales price, or the actual value
received from such admissions, which 6 percent shall be
added to and collected with all such admissions from the
purchaser thereof, and such tax shall be paid for the

exercise of the privilege as defined in the preceding
paragraph. Each ticket must show on its face the actual
sales price of the admission, or each dealer selling the
admission must prominently display at the box office or
other place where the admission charge is made a notice
disclosing the price of the admission, and the tax shall be
computed and collected on the basis of the actual price of
the admission charged by the dealer. The sale price or
actual value of admission shall, for the purpose of this
chapter, be that price remaining after deduction of federal
taxes, if any, imposed upon such admission, and the rate of
tax on each admission shall be according to the brackets
established by s. 212.12(9).

(c) The provisions of this chapter that authorize a taxexempt sale for resale do not apply to sales of admissions.
However, if a purchaser of an admission subsequently
resells the admission for more than the amount paid, the
purchaser shall collect tax on the full sales price and may
take credit for the amount of tax previously paid. If the
purchaser of the admission subsequently resells it for an
amount equal to or less than the amount paid, the purchaser
shall not collect any additional tax, nor shall the
purchaser be allowed to take credit for the amount of tax
previously paid.... (Emphasis supplied)

Section 212.02(1), F.S., defines "admissions," and provides in
pertinent part:

The term "admissions" means and includes the net sum of
money after deduction of any federal taxes for admitting a
person or vehicle or persons to any place of amusement,
sport, or recreation or for the privilege of entering or
staying in any place of amusement, sport, or recreation,
including, but not limited to, theaters, outdoor theaters,
shows, exhibitions, games, races, or any place where charge
is made by way of sale of tickets, gate charges, seat
charges, box charges, season pass charges, cover charges,
greens fees, participation fees, entrance fees, or other
fees or receipts of anything of value measured on an
admission or entrance or length of stay or seat box

accommodations in any place where there is any exhibition,
amusement, sport, or recreation.... (Emphasis Supplied)

The taxpayer sells golf packages to resort guests. The golf
packages, which are admissions, are separately itemized on the
invoice to the guest, and are not for the use of transient
accommodations. Section 212.04(1)(c), F.S., cited above, does
not allow the tax exempt purchase of an admission for resale.
You are correct in stating that the golf course will collect tax
from the taxpayer on the sale of the admission. Assuming that
the taxpayer is reselling the admission to the guest for more
than the admission was purchased for, you are correct that the
taxpayer will collect tax on the admission charge to the guest,
then take credit for tax paid to the golf course against the
taxes due to the department.

This response constitutes a Technical Assistance Advisement
under Section 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 Section 213.22, F.S. Our
response is predicated upon 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 from that which is 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 Section 213.22,
F.S. Your name, address, and any other details that 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 this response.

Sincerely,

Sara D. Faulkenberry
Tax Law Specialist

Technical Assistance and Dispute Resolution
850/414-9838
[email protected]

Control #33841