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Keywords

statutetax lawlegislative intentappellant

statutesustainedappellant

Related Cases

Ryder Truck Rental, Inc. v. Bryant, 170 So.2d 822

Facts

The appellants, engaged in renting motor vehicles, challenged the interpretation of the 1963 amendments to the sales and use tax law, which altered the tax treatment of motor vehicles. Previously, motor vehicles were exempt from sales tax, but the 1963 amendments imposed a two percent tax on sales and a three percent tax on rentals. The appellants argued that these changes were not intended to create a new tax burden and that the title of the act did not adequately reflect the changes made.

The appellants are engaged in the business of renting—on an hourly, daily, weekly, monthly or yearly basis—motor vehicles which they purchase and to which they retain title during the entire useful life of the vehicle.

Issue

Whether the title of the amendatory act was defective and whether the amendments to the sales and use tax law imposed a new tax on the sale of motor vehicles purchased exclusively for rental purposes.

The appellants contended below, and here contend, that the ‘minor changes' made in Section 212.08(3), supra, by the 1963 Legislature were intended only to change the rate of taxation of rentals of motor vehicles (from one to two percent) and were not intended to ‘add a new tax’ on appellants and others similarly situated.

Rule

The title of an act must adequately inform the public of its contents, and legislative intent must be derived from the clear language of the statute.

It has been said that the reason for the requirement made by Section 16 of Article III ‘is simply to indicate to one who reads the title the general nature and substance of the content of the body of the statute.’

Analysis

The court analyzed the language of the amendatory statute and determined that the legislature intended to revoke the previous administrative interpretation that exempted the sale of motor vehicles purchased exclusively for rental purposes. The court found that the title of the act sufficiently warned the public about the changes regarding the taxation of motor vehicles, thus upholding the amendments.

Conclusion

The Supreme Court affirmed the lower court's decision, ruling that the title of the act was not defective and that the amendments to the sales and use tax law were valid.

Accordingly, it must be held that the Chancellor did not err in so holding.

Who won?

The State Revenue Commission prevailed in the case because the court upheld the interpretation of the 1963 amendments to the sales and use tax law, confirming that the changes were valid and properly enacted.

The Chancellor, in a well considered opinion and Declaratory Decree, sustained the Commission's interpretation of the effect of the 1963 amendments and found, also, that the title was not violative of Section 16 of Article III, supra.

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