District Court of Appeal of Florida December 20, 1983, No. AS-390 (United Parcel Service, Inc. v. State, Office of the Comptroller)

MILLS, Judge.

United Parcel Service (U.P.S.) appeals from the Comptroller’s final order that determined which U.P.S. vehicles were subject to the partial exemption provided by Section 212.08(9), Florida Statutes (1979), established the ratio formula to be used in computing the use and sales tax due on the vehicles under Section 212.08(9) and denied U.P.S.’s claim for a sales tax refund.