Alachua County, Petitioners v. Expedia, Inc., Respondents — Lewis, J., Dissenting

Summary

Justice Lewis dissented, concluding that Florida's tourist development tax applies to the full amount an online travel company charges a customer for a hotel reservation, including the company's markup. He reasoned that the statute taxes the total consideration charged for occupancy, and that the substance of the transaction is the customer's payment for the right to occupy the room. Justice Pariente, concurring in the result, agreed that only the amount received by the hotel is taxable but would have reached that result by construing statutory ambiguity in favor of taxpayers.