District Court of Appeal of Florida March 3, 1995, No. 94-4 (Central Florida Investments, Inc. v. Department of Revenue)

PETERSON, Judge.

The issue to be determined in this appeal is whether the excise tax imposed by section 201.08(1), Florida Statutes (1991), must be paid even though the separate mortgage securing it is unrecorded.

Central Florida Investments, Inc. (“CFI”), is a timeshare developer which, in the course of selling timeshares, receives promissory notes for a portion of the sales price.