Circuit Court for the Judicial Circuits of Florida April 30, 1986, Case No. 83-31781 CA 06 (Land v. State of Florida Department of Revenue)

OPINION OF THE COURT

JOSEPH J. GERSTEN, Circuit Judge.

This cause came before the Court for non-jury trial on March 27, 1986. The Court heard testimony and received documentary evidence adduced by the parties and considered the oral and written arguments advanced by the parties. Upon consideration, the Court makes the following findings and conclusions:

*161.