If a property owner enters into a lease agreement with a finance company to make land improvements and then leases the improved property back to the owner with rent payments covering the finance costs, the agreement is not subject to tax. In the state of Florida, this type of arrangement is considered a mortgage rather than an operating lease. The agreement cannot be considered a lease because the business of the lessor is not real property leases, “amortization of the debt” is the only substance to the agreement, the lessee is responsible for any obligations of ownership, risk, and maintenance, and all payment obligations are “absolute and unconditional”. (Technical Assistance Advisement, No. 02A-029, Florida Department of Revenue, June 28, 2002)