District Court of Appeal of Florida October 26, 1995, No. 94-1100 (Chapparal Partners ex rel. First Interstate Bank of California v. State, Department of Revenue)

BARFIELD, Judge.

The appellant, Chapparal Partners, is a general partnership composed of Congden Properties, Inc. and First Interstate Bank of California as trustee for Trust Number 7413127. First Interstate Bank held defaulted notes and mortgages on two properties in Jacksonville, Florida, which were worth substantially less than the amount of indebtedness due on the notes.