In First Union National Bank of Florida v. Ford, 636 So. 2d 523 (Fla. 5th DCA 1993), the Fifth District Court resolved a case it described as "the reverse or mirror image of Hialeah, Inc. v. Dade County." The case concerned taxation of property that Brevard County used "as its primary governmental and administrative offices." Id. at 523. The county utilized a financing arrangement "whereby individual investors purchased certificates of participation to raise sufficient funds to build" the county governmental center on donated land. Id. at 524. Title to the land was held by the First Union Bank as trustee for the holders of the certificates of participation. Id. The property was leased by the bank to the county for a projected twenty-five-year term, running from year to year and automatically renewable. Id. Rental payments made by the county were used solely to retire the principal and interest on the debt owed to the owners of the certificates of participation. Id. Under the terms of the lease, once the indebtedness was paid in full, the "Bank must convey legal title to the property in fee to the County." Id. The Fifth District concluded "that the County has retained sufficient rights and duties regarding the realty and its improvements, to make it the equitable owner." Id. The court focused on the fact that "neither the Bank nor the certificate holders have a right nor prospect of ever occupying or using the land and buildings" and reasoned that "the County holds substantially all the burdens and benefits of ownership relating to the property sought to be taxed." Id. at 524, 527. Accordingly, the Fifth District held that the bank was not liable for ad valorem tax on the property. Id. at 527.