Muben-Lamar, a New Jersey limited partnership, paid more than $200,000 in Florida documentary stamp taxes on the transfers of three office buildings/shopping centers in Dade and Volusia Counties. It sought a refund of the tax on grounds the partnership was merely a vehicle by which the owners would manage the buildings and that Muben-Lamar offered nothing in consideration for them. The Department denied the refund, and the trial court and First District Court upheld this ruling.