The petition for review is GRANTED and the order of the hearing officer is QUASHED. State Dep’t of Revenue v. Miami Nat’l Bank, 354 So.2d 84 (Fla. 1st DCA 1977).

concurring specially.

I concur in the foregoing opinion only because a majority of a panel of this Court decided the question here involved in State Department of Revenue v. Miami National Bank, 354 So.2d 784 (Fla. 1st DCA 1977). Although I dissented from that opinion, the majority opinion is now the law of this Court.