OIG No. 23-16: Investigation of Certificate of Use and Business Tax Receipt for 1330 15th StreetJoseph M. Centorino, Inspector General
To: Honorable Mayor and Members of the City Commission
From: Joseph M. Centorino, Inspector General
Re: Investigation of Complaint and Review of Process Regarding Issuance of Certificate of
Use and Business Tax Receipt for 1330 15" Street
OIG No. 23-16
Date: August 18, 2023
EXECUTIVE SUMMARY
The Miami Beach Office of the Inspector General (OIG) has concluded an investigation and
process review arising from a complaint made by Ananthan Thangavel, owner of the property
located at 1330 15" Street, Miami Beach, which alleged that (1) City of Miami Beach employees
may have engaged in malfeasance and/or negligence with respect to the issuance of a Certificate
of Use (CU) /Business Tax Receipt (BTR) for the property; (2) an employee of permit expediter,
Permit Doctor, forged the CU/BTR application that was submitted to the City and; (3) a City of
Miami Beach Planning and Zoning employee instructed the Miami Beach Police Detective looking
into the forgery allegation not to investigate the matter.
Allegations two and three were unsubstantiated. The allegation of forgery was reported by Mr.
Thangavel to the Miami Beach Police Department (MBPD). After reviewing the information
provided, MBPD determined that the matter was civil in nature, and did not proceed with a criminal
investigation, a decision with which the OIG agrees based on its investigation. Regarding the
allegation that an employee improperly instructed the MBPD Detective assigned to the complaint
not to investigate the matter, both the Detective and the employee involved denied any such
instruction, and the OIG found no evidence of any such misconduct.
The first allegation, the issuance of the CU/BTR to Mr. Thangavel, was thoroughly reviewed by
the OIG, which concluded that there was no malfeasance or neglect by City employees; however,
it did determine that a series of events occurred that led to Mr. Thangavel's obtaining a CU/BTR
for a use of the property for which he did not intend to apply. The OIG found that
miscommunication, misunderstanding, and/or a misinterpretation of the various meanings of
accommodation establishment terminologies throughout the process by Mr. Thangavel and the
Permit Doctor employees, the delay in time caused by the pandemic, and a lack of sufficient
quality controls on the part of the City resulted in Mr. Thangavel's obtaining a CU/BTR for
"APARTMENT ROOMS" (non-transient) instead of one for "HOTELS (SMOKE DETECTOR)"
which was the type of CU/BTR that the previous owner was issued to operate a suite hotel at that
location.
The OIG reviewed voluminous documentation, including, but not limited to, City records from
Planning and Zoning, Finance, Building, Code Compliance, emails, and open-source records and
interviews and communications with Mr. Thangavel, City staff, Permit Doctor staff, and the State
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of Florida Department of Business and Professional Regulations Licensing staff. The investigation
and review of the decision to issue Mr. Thangavel the CU/BTR for apartment rooms focused on
the CU/BTR application that was changed by an employee of the Permit Doctor from the original
application prepared by Mr. Thangavel and submitted to the City by the Permit Doctor employee
on behalf of Mr. Thangavel.
At all times during Mr. Thangavel's pursuit to obtain a CU/BTR to operate a business in Miami
Beach, the operation of short-term rentals has been prohibited in the area of the City in which Mr.
Thangavel's property is located. However, the operation of suite hotels (a short-term rental
method) which is what the previous owner was licensed to operate, was permitted until an
ordinance prohibiting its use became effective on August 25, 2020.
The OIG learned that the CU/BTR process that was in place in 2019 during the time of this review
has changed, and the current process for customers to apply is predominately completed online
through a software system called Citizen Self-Service (CSS) accessed on the City's website. The
current process requires that a Certificate of Use be issued prior to applying for a Business Tax
receipt which were both requested on a single application. The OIG also learned that the City has
engaged consultant Berry Dunn, which is currently conducting a review of the City's regulations
and processes relating to development review. They will be evaluating the City's current business
practices, which include the CSS, and will be providing recommendations for service
improvement.
This OIG report presents its observations of the processes that led to miscommunication,
misunderstanding, and/or misinterpretation among those involved, as well as some quality control
issues within the City that may still exist in the current process and will provide recommendations
that may contribute to Berry Dunn's efforts toward service improvements.
The report concerns issues that are also the subject of an administrative appeal currently pending
before the City of Miami Beach Board of Adjustment. Pursuant to Article I, Section 2 of the Related
Special Acts, and Sections 118-9 and 118-397 of the Land Development Regulations, the Board
of Adjustment has the exclusive jurisdiction to decide appeals from formal determinations of the
Planning Director.
On February 22, 2023, the owner of the property at 1330 15th Street appealed the denial of a
Business Tax Receipt on the basis that, pursuant to the Land Development Regulations, short-
term rentals are not permitted on the subject property. On May 5, 2023, following argument and
testimony from the property owner, Planning Director, and nearby residents, the Board of
Adjustment denied the appeal and affirmed the decision of the Planning Director.
On June 2, 2023, the Board of Adjustment adopted a motion to reconsider its May 5th decision.
Pursuant to that motion, the appeal will be re-noticed for the September 8, 2023, Board of
Adjustment meeting. At that time, the Board will take additional testimony, and decide on any
further action.
The relevant governing authorities referred to in this report are included in Appendix A.
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OIG Authority
Section 2-256 of the Code of Miami Beach codifies that the City of Miami Beach Office
of Inspector General is created as an independent body to perform investigations, audits,
reviews, and oversight of municipal matters, including city contracts, programs, projects, and
expenditures, in order to identify efficiencies and to detect and prevent fraud, waste,
mismanagement, misconduct, and abuse of power. The organization and administration of the
office must be sufficiently independent to assure that no interference or influence external to the
office adversely affects the independence and objectivity of the inspector general.
The OIG has the power to require reports from the city manager, city departments, city agencies,
boards, and committees, and city officers and employees, regarding any matter within the
jurisdiction of the inspector general. The OIG has the power to subpoena witnesses, administer
oaths, and require the production of records regarding any matter within the jurisdiction of the
office.
Background
This matter originated from a complaint received by the OIG in April 2023 from the current owner,
1330 15" Street, LLC (Ananthan Thangavel), of the property located at 1330 15" Street, Miami
Beach, which included the allegations presented in the summary. In November 2019, Mr.
Thangavel purchased the property, which was converted by the previous owner from a four-unit
residential apartment to an eight-unit suite hotel. In January 2019 the previous owner submitted
an application for a CU/BTR (Exhibit 1) and, in February 2019, was issued a CU/BTR (Exhibit 2)
and in May 2019, a Certificate of Occupancy (CO) (Exhibit 3) by the City to operate a suite hotel.
The previous owner also applied for and inadvertently received a hotel license from the State of
Florida Department of Business and Professional Regulation (DBPR), which will be discussed in
detail below.
Within six months of obtaining the CO, the previous owner sold the property to Mr. Thangavel.
After purchasing the property, Mr. Thangavel engaged a local permit expediting company, Permit
Doctor, to assist him in transferring and obtaining the proper license to operate the business in
the City of Miami Beach. Between November 2019 and October 2021, Mr. Thangavel personally
and/or through the Permit Doctor initiated and navigated the process to obtain a CU /BTR to
operate a business at the property.
On September 4, 2019, prior to Mr. Thangavel's engagement with the Permit Doctor, the City's
Planning Director, Thomas Mooney, responded to a request by Pathman Lewis, LLP, on behalf
of Mr. Thangavel, for a zoning verification for the property that is the subject of this review. The
property is located at 1330 15" Street, Miami Beach, Florida. In his response, Mr. Mooney stated:
Please be advised that the subject property is currently zoned RM-1, Residential -
Multi Family, Low Intensity and has a future land use designation of RM-1,
Residential - Multi Family, Low Intensity. This district is designed for low intensity,
low rise, single and multi-family residences.
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In accordance with Section 142-152 of the Land Use Regulations of the Code of
the City of Miami Beach, the main permitted uses in the RM-1 District include:
single-family detached dwelling; townhomes: apartments; and bed and breakfast
inn (pursuant to article V, division 7 of this chapter).
The subject property is also located within the West Avenue Bay Front Overlay
District. I have attached a copy of Chapter 142, Article Ill, Division 5 of the City's
Land Development Regulations, which pertain to the West A venue Bay Front
Overlay District.
The West Avenue Bay Front Overlay District permits the adaptive reuse of existing
single-family and multi-family residential structures for suites hotels, in accordance
with Section 142-845 of the City's Land Development Regulations (attached). The
City's Land Development Regulations defines a suite hotel unit and suite hotel as
a room, or group of rooms, each containing separate bathroom and full cooking
facilities, with ingress and egress which may or may not be through a common
lobby, intended for rental to transients on a day-to-day, week-to-week, or month-
to-month basis, and not intended for use or used as a permanent dwelling.
The subject property is not located within a local historic district. However, any
proposed development shall require the review and approval of the Design Review
Board.
Mr. Mooney's letter, written on September 4, 2019, indicates in bold lettering that suite hotels, as
defined, were permitted at the location of the property. Although Mr. Mooney's letter does not
specifically state it, short-term rentals were not and are not a permitted use at the address where
Mr. Thangavel's building is located.
The OIG's review revealed no evidence that Mr. Mooney's letter was considered by Mr. Thangavel
and/or shared with the Permit Doctor employees during the pursuit of the CU/BTR to operate in
the City. Had this letter been considered and utilized to inform them about the permitted uses at
the location of Mr. Thangavel's building, the events that followed and ultimately resulted in Mr.
Thangavel's obtaining a CU/BTR for which he did not intend to apply could have been avoided.
Certificate of Use and Business Tax Receipt Process 2019
In order to operate a business in the City of Miami Beach, a business owner must obtain a
Certificate of Use (CU), which allows for the specific use of a building and certifies that the use is
in compliance with all applicable city codes, regulations, and ordinances. The owner must also
obtain a Business Tax Receipt (BTR), which is the method by which the City grants the privilege
of engaging in or managing any business, profession, or occupation within the City.
To understand the process that the City used in 2019 to intake, process, and issue a CU and
BTR, the OIG met with various Miami Beach staff members, including Thomas Mooney, Planning
Director, Ricardo Guzman, Principal Planner, and Sasha Gonzalez, Finance Department
Customer Service Manager. Through these meetings, the staff members related that in 2019 the
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application for a CU and BTR was completed on one form titled "City of Miami Beach Certificate
of Use (CU), Annual Fire Inspection Fee & Business Tax Application." The form was submitted to
the Finance Department Customer Service Section. The intake of the application would occur
with no initial action by the Finance Department.
The received application would be uploaded into the City's software application (EnerGov) which
is used by the Finance, Planning, Building, and Code Compliance Departments to process and
review the CU/BTR submittals. Once the application is uploaded, a BTR number is generated for
that process, and the system automatically creates a "plan case" known as a BLPL. The BLPL is
routed to the regulatory disciplines, which require review and/or inspections for the approval of
the CU part of the process. Once the review and inspections have been completed and have
passed for the issuance of a CU, the Finance Department ensures that all documentation required
for the BTR is received and reviewed, and then the CU/BTR is issued to the owner.
Certificate of Use and Business Tax Receipt 1330 15 Street - Mr. Thangavel
Permit Doctor
In November 2019, Mr. Thangavel engaged the Permit Doctor, a permit expediting company
located at 775 17 Street, Miami Beach, to assist him in transferring and obtaining the proper
permits and/or licenses to operate a business in the City of Miami Beach. Between November
2019 and October 2021, Mr. Thangavel, through the Permit Doctor and sometimes personally,
initiated and navigated the process to obtain a CU/BTR from the City. Throughout the
engagement with the Permit Doctor, Mr. Thangavel interacted with Mr. Damien Gallo Jr., who is
the son of the owner of the Permit Doctor, and Ms. Eugenia (Jenny) Suraeva, permit runner.
During an interview with the OIG, Mr. Gallo Jr. stated that he met with Mr. Thangavel in person
on only one occasion and that all other communications were conducted by telephone or email.
Mr. Gallo Jr. related that his services were secured based on a referral from the law firm Pathman
Lewis to assist Mr. Thangavel in getting the property at 1332 15" Street licensed for short-term
rentals. He recalls that he and Ms. Suraeva submitted applications for a license with the State of
Florida and that they started the process with the City of Miami Beach. However, the process was
interrupted due to the pandemic, and his communication with Mr. Thangavel ended over a year
ago.
According to the emails reviewed by the OIG, Mr. Gallo Jr. was involved in the process from
December 2019 through October 2021. Mr. Gallo Jr. recalled that he participated in the inspection
process for both the state and city at the property. He did not recall specifically which documents
he submitted and in which parts of the process he or Ms. Suraeva participated. During the
interview, Mr. Gallo Jr. informed the OIG that it was his belief that Mr. Thangavel wished to pursue
the licensing of short-term rentals.
Mr. Gallo Jr. did not recall having any conversations with Mr. Thangavel about suite hotels, and
none of the emails or documents reviewed by the OIG mention suite hotels. Mr. Gallo Jr. advised
that he did not recall ever being involved with licensing a suite hotel. He said he was unfamiliar
with the term suite hotel and did not know the difference between a suite hotel and a short-term
rental. While discussing suite hotels during the interview, Mr. Gallo Jr. stated, "Maybe our
terminology, we also call it as a short-term, and that could be an error." He indicated that the
Page 5 of 23
process to obtain a CU/BTR was never completed, yet Mr. Thangavel was issued a CU/BTR for
apartment rooms on May 19, 2020 (Exhibit 4). Mr. Gallo did not recall the details and could not
explain how that CU/BTR was ultimately issued.
Mr. Gallo Jr. was shown a copy of the CU/BTR application that was completed by Mr. Thangavel,
dated November 18, 2019 (Exhibit 5). He does not recall the specific application but
acknowledged that he is familiar with the application and would have had to receive it from Mr.
Thangavel in order to pursue the licensing.
On the first page of the application, the type of application was indicated as "Change of Owner,"
the application checklist is blank, and the section that asks if the application involves a "Change
of Use" was not checked, the type of business was indicated as "Hotel," and the specific
description of the business was blank, as depicted in the image below. The second page of the
application was additional information and Mr. Thangavel's signature and date.
City of Miami Beach
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Mr. Gallo Jr. was then shown a copy of the CU/BTR application that was ultimately submitted to
the City to be processed and acted upon (Exhibit 6). The handwriting on the first page of this
application is different from the original, the type of application was indicated as "Change of
Owner," the application checklist was blank, the section that asks if the application involves a
"Change of Use" was not checked, the type of business was not indicated, and the specific
description of the business was "Short-term rental," which is lined through, and "Apt Bldg" is
written in below it, in what appears to be yet a different handwriting as depicted in the image
below.
Page 6 of 23
This ookoon is NOH your business tax rt¢cot 0o not operate re business ntt the Certlic ewe o use and to sinets Tex Receipt
a coed
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Type at#Application:
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The second page of the application is a duplicate of the original application completed by Mr.
Thangavel. Mr. Gallo Jr. stated that he did not complete the document and does not know who
did. He acknowledged that one of his employees, possibly permit runner Jenny Suraeva, may
have made the change.
During a separate interview with Ms. Suraeva, she was shown the same two CU/BTR
applications, and she also did not recall the details of everything she did regarding the process
for Mr. Thangavel but stated that she did participate in the process to obtain a CU/BTR. She
stated that she was the one who changed the first page of Mr. Thangavel's application, combined
it with the original second page signed by Mr. Thangavel, and submitted it to the Finance
Department of the City on December 27, 2019. She did not recall the specific circumstance in
which the change was made but stated that she would not have changed the document without
the approval of Mr. Thangavel. She did not recall how she obtained the approval. She stated that
the addition of "Apt Bldg" was not her handwriting and did not recall the circumstances in which
that was done.
Mr. Thangavel denied providing such approval, or adding "Apt Bldg" to the document, or seeing
the document at the time it was submitted. Both Mr. Gallo Jr. and Ms. Suraeva stated that all of
the documents and email transactions regarding the process with Mr. Thangavel have been
deleted or destroyed, as they only maintain the documents for two years.
The OIG has been unable to determine who wrote "Apt Bldg" on the application. No one from the
City acknowledges making the change, however, the change was made prior to the application
being uploaded into the system by the Finance Department.
During their respective interviews, Mr. Gallo Jr. and Ms. Suraeva were both shown copies of
CU/BTR applications for each of the eight units in Mr. Thangavel's building that he completed and
signed and are dated November 18, 2019 (Exhibit 7 Unit 1). On the first page of this application,
the type of application was indicated as "Change of Owner," and the application checklist is blank.
Page 7 of 23
The section that asks if the application involves a "Change of Use" is not checked. The type of
business is indicated as "Hotel," and the specific description of the business is "Short-term
Rental," as depicted in the image below.
City of Miami Beach
Certificate of Use (CU) Annual Fire Inspection Fee & Business Tax Application
This eop eton is QI your busress tar roccit. Do not operate the business unt the Cert.ht ot Use ud te Business Ta Receipt e are
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Type of Application.
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The second page of the application contains additional information and Mr. Thangavel's signature
and date. Each of the applications indicates a unit number one through eight. Both Mr. Gallo Jr.
and Ms. Suraeva recognized the applications but did not recall when they were received or what
happened with them. They related that the City's process required separate CU/BTRs for each
unit to be used for a short-term rental; however, these applications were never submitted to the
City.
During his interview, Mr. Gallo Jr. was shown eight copies of applications for Certificates of Use
(CU) that were submitted electronically through the City's Citizen Self-Service (CSS)1portal on
September 24, 2021. The applications were for Mr. Thangavel's eight-unit property. The applicant
was Damian Gallo, and the business description was "Short-term rental". Mr. Gallo Jr. again
recognized and acknowledged that he submitted the applications but did not recall the specifics.
After being shown a series of emails in which he and Mr. Thangavel were discussing the process
and that it had not been completed, he recalls moving forward with these particular applications.
However, by that time, Mr. Thangavel had already been issued a CU/BTR from the City for
"apartment rooms" on May 19, 2020, based on the CU/BTR application that was submitted by
Ms. Sureava on December 27, 2019, which was renewed by Mr. Thangavel effective December
20, 2020.
1 The City's process for applying for Certificates of Use and Business Tax Receipts was bifurcated and the application process began to be
executed through an online system on the City's website called "Citizen Self-Service."
Page 8 of 23
On October 7, 2021, all of the electronically submitted CU applications for short-term rentals that
were submitted by Mr. Gallo Jr. were denied because short-term rentals were not then and are
not now permitted at the location of Mr. Thangavel's building.
One of the documents uploaded with the electronic application submitted by Damien Gallo Jr.
was a copy of a letter dated June 15, 2020, signed by Mr. Thangavel that stated the following:
I, owner of 1330 15th Street, LLC would like to apply and operate short term
vacation rentals in each of the units on property. The unit numbers are as follows;
1,2 3, 4,5, 6, 7, 8. Should you have any questions please don't hesitate to contact
me directly.
Short-term rentals have not been authorized in the location of Mr. Thangavel's building since
2010. Had the City been in possession of such a letter when the application that was relied upon
to issue the CU/BTR to Mr. Thangavel was received in 2019, he might have been informed by the
City that short-term rentals were not permitted, and could then have inquired and proceeded with
obtaining a license to operate a suite hotel which was still permitted at the time.
At no time during the process to obtain his CU/BTR did Mr. Thangavel or any Permit Doctor
employee obtain or review a copy of the CU/BTR application that was submitted by the previous
owner that resulted in a CU/BTR for "HOTELS (SMOKE DETECTOR)" being issued for the
operation of a suite hotel.
That application indicates that it is for a "Hotel," and the specific use is identified as "SUITE
HOTEL," as depicted in the image below.
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Page 9 of 23
State of Florida License
Florida Statute 509.241 (2) requires that each person who plans to open a public lodging
establishment or a public food service establishment a
pply for and receive a license from the Department of Business and Professional Regulation
(DBPR) Division of Hotels and Restaurants prior to the commencement of operation. The
previous owner submitted an application for a hotel license with DBPR and was issued hotel
license number HOT2329406 on November 29, 2018. That license was submitted to and
considered by the City when it issued the CU/BTR to the previous owner for "HOTELS."
Mr. Gallo Jr. submitted an application that Mr. Thangavel signed and dated November 18, 2019,
to DBPR for a hotel license. The application indicated that it was for a "Hotel" and that it was for
a "Change of Ownership." The previous owner's license number and information were provided
on the application.
On December 17, 2019, a DBPR inspector sent the following email to the Deputy District Manager
of the DBPR's Miami Office:
As per our conversation, could you please re-profile this account to a TAPT, this
is a 8 units building, 1 mop sink, no office, no Public bathroom, and it will (sic) used
as a Short (sic) Rental Apts.
The Deputy District Manager then sent the following email to the licensing team:
Please re-profile this account from a Hotel to a transient apartment. There are no
signs advertising establishment as a hotel and no front desk for guest to check in.
The establishment was licensed as a hotel under previous owner, but is actually
an eight unit transient apartment. Inspector spoke with new owner and he is o.k.
with license being reclassified correctly.
Mr. Thangavel was issued "TRANSIENT APARTMENT" license number TAP2330379 by DBPR
on December 18, 2019, and has renewed the license each year. The current license expires on
October 1, 2023.
Florida Statute 509.242 (1) (a) classifies a "Hotel" as follows:
any public lodging establishment containing sleeping room accommodations for
25 or more guests and providing the services generally provided by a hotel and
recognized as a hotel in the community in which it is situated or by the industry.
Florida Statute 509.242 (1) (e) classifies a "Transient apartment" as follows:
a building or complex of buildings in which more than 25 percent of the units are
advertised or held out to the public as available for transient occupancy,
'Transient Occupancy" is defined in Florida Statute 509.013 (4)(a)(1) as follows:
any unit, group of units, dwelling, building, or group of buildings within a single
complex of buildings which is rented to guests more than three times in a calendar
year for periods of less than 30 days or 1 calendar month, whichever is less, or
which is advertised or held out to the public as a place regularly rented to guests.
Page 10 of 23
The previous owner was improperly issued a hotel license by the State of Florida, which was
considered by the City when it issued the CU/BTR for "HOTELS." The "TRANSIENT
APARTMENT" license that Mr. Thangavel was issued and currently holds allows for transient
rental, however, he was issued a CU/BTR for residential apartments, non-transient use.
Application Intake
The application that was submitted to the City was the application that was altered from the
original by Permit Doctor employee Ms. Suraeva. The application was further altered by an
unknown person. A review of the information regarding the intake of the application provided by
Finance Customer Service Manager Sasha Gonzalez and of information available in the City's
EnerGov system revealed that the application workflow process was started, a BTR completeness
check was completed, and the application with attachments was scanned into the system on
December 27, 2019.
The attachments to the application included copies of a warranty deed, corporate filing, federal
tax identification information, and a State of Florida license issued on December 18, 2019, by the
Florida Department of Business and Professional Regulation (DBPR) Division of Hotels and
Restaurants for a "TRANSIENT APARTMENT." Also uploaded on the same date was a copy of
the previous CU/BTR, which was issued to the previous owner on September 27, 2019, and
expired on September 30, 2020. The previous CU/BTR was for the specific use of "HOTELS
(SMOKE DETECTOR)." There is no mention of a suite hotel in the document.
The application was accepted and uploaded into the system, although it had been altered; pages
one and two had different handwriting, and the page one form version was" FORM OCC-1 Rev.
09/13/16, while page two was "FORM OCC-1 Rev. 10/12/04. Sasha Gonzalez, Finance
Department Customer Service Manager, informed the OIG that the alteration of the specific type
of business from "short term" rental to "Apt Bldg" on the submitted application would not have
been made by anyone in the Finance Department as it is the Planning Department that determines
the use. The application with the alteration in question was uploaded into the system by the
Finance Department. The Chief Financial Officer informed the OIG as follows:
the initial intake of an application is processed by one employee, and the final
issuance of the BTR is not released until a supervisor has reviewed the application
for thoroughness. A review of the EnerGov system demonstrates that this
particular BTR application was processed by a Financial Analyst I and
subsequently reviewed by a Financial Analyst II, and ultimately reviewed by a
Financial Analyst Ill before being issued.
The altered application, as described above, was initially accepted and made its way through two
additional reviews within the Finance Department without being questioned.
Finance Review
The application that the Finance Department received was a single application for both a
Certificate of Use and a Business Tax Receipt. The application was reviewed at intake for its
thoroughness. It was then uploaded into the EnerGov system by a Finance staff member, and the
system generated a BTR number, BTR008501-12-2019, and a BLPL case number, BLPL2019-
08005. This began the process for the Planning, Code Enforcement, Building, and Fire
Page 11of 23
Departments to conduct their reviews and/or inspections in order for the CU/BTR to be issued.
The Finance Department would ultimately review the application again at the end of the process
for the issuance of the BTR.
Planning Review
Although each of the above reviews and inspections is important, the foremost review is for the
Certificate of Use (CU), which the Planning Department conducts. It is here that the specific use
for a specific location is reviewed and determined, and where the Planning Department certifies
that the use is in compliance with all applicable city codes, regulations, and ordinances. The
Business Tax Receipt (BTR), which is the license to do business in Miami Beach, is issued based
on the CU and the State license (if applicable).
In this instance, the information contained in the EnerGov system history shows that the planning
review was conducted on December 30, 2019, and was completed on the same day. There are
no internal notes or evidence of communication with Mr. Thangavel or anyone from the Permit
Doctor. The only contact information listed is for Mr. Thangavel. There is one file attached which
is the previous BTR that lists the use as "HOTELS."
The records relating to BTR008501 for Mr. Thangavel's application were available to review
through the "Linked Records" icon. The attachments that were available for review included the
application with attachments and the previous BTR. The only comments regarding this review
appear in the "History" section. The comment reads, "Residential Apartment Building -8 units."
There is no explanation of how that determination was made, however, the only place the word
apartment appears is on the modified application as "Apt Bldg" and the license issued by the State
which states, "TRANSIENT APARTMENT."
The individual who conducted the review is no longer with the City. An email sent to an attorney
representing Mr. Thangavel on June 22, 2022, by Ricardo Guzman, Principal Planner for the City,
in the summary of events, states as follows:
"On December 30, 2019: BLPL2019-08005 was approved for 8 residential
apartment units (non-transient). This is the precursor for the new CU and BTR. (no
supporting documentation provided or requested by the City to support the change
of use)."
Mr. Guzman does not have independent knowledge of the details of how this planning review was
conducted. The application itself indicates that it is for a "Change of Ownership." The section that
states, "Does this Application involve: Change of Use" is not checked to indicate that it is not
a change of use but simply a change of ownership. In fact, none of the applications that were
completed by either Mr. Thangavel or Ms. Suraeva, whether they were submitted or not, indicate
that the application is for a change of use. The previous BTR identifies the use as "HOTELS."
There was no documentation requested or provided supporting the change of use and no
evidence that a clarification was sought by anyone in the Planning Department prior to changing
the use to "APARTMENT ROOMS."
Page 12 of 23
Building Review
The information contained in the EnerGov system history shows that the building review was
conducted on December 30, 2019, and was completed on the same day. There are no internal
notes. There is one file attached which is the previous BTR that lists the use as "HOTELS." The
records relating to BTR008501 for Mr. Thangavel's application were available to review through
the "Linked Records" icon. The attachments that were available for review included the
application with attachments and the previous BTR. The only comments regarding this review
appear in the "History" section. The comment reads, "OK per CO19-1320" which refers to the
Certificate of Occupancy that was issued to the previous owner on May 14, 2019, which states in
the certificate description and specific conditions section the following:
CO - BC1806547 - Units 101-103, 201-204/ interior remodeling of existing
building. units 101-103 and 201-204 conversion to suite hotel. Existing 4 units to
new 8 units.
The reviewer, Senior Building Inspector Gabi Chamoun, was interviewed by the OIG and informed
the OIG that there was no need to change the Certificate of Occupancy (CO) as the requirements
for a suite hotel or hotel occupancy are stricter than the requirements for apartment occupancy.
Under the existing CO, the owner in the future could apply to change the use from apartment to
hotel if it is authorized.
Fire Inspection
The information contained in the EnerGov system history shows that the initial fire inspection of
Mr. Thangavel's building was conducted on December 31, 2019. The inspection failed and the
building was reinspected on January 7, 2020, and failed again. On April 10, 2020, the building
was reinspected and passed. As part of the process, Mr. Thangavel was required to submit to
the Miami Beach Fire Prevention Division a completed Annual Single Station Smoke Detectors
Inspection/Test Report. That report was completed and dated April 2, 2020. In the section of the
form, "TYPE OF OCCUPANCY (SPECIFIC USE)", it states, "Short-term rental" (Exhibit 8).
CUIBTR Issuance
The final step in the process ends where it began--with the Finance Department--for the issuance
of the CU/BTR. The information contained in the EnerGov system history shows that this took
place on May 19, 2020. An email was uploaded in the system that was sent to Mr. Thangavel on
May 19, 2020, from an employee who is no longer with the City, which informed Mr. Thangavel
that the only thing left to complete for the issuance of the BTR was payment and the resort tax
application. The system shows that all required fees were paid, and the attachments included
the email message referenced above and the completed smoke detector form (Exhibit 8)
referenced above. It also included a copy of the issued CU/BTR license number BTR008501-12-
2019 issued to 1330 15" Street LLC on May 19, 2020, for code 95000900 "APARTMENT
ROOMS" and code 95700000 "Apartment buildings (rental), not including kitchens and
bathrooms" (Exhibit 4 ).
The process began on December 27, 2019, and the CU/BTR was issued on May 19, 2020. As
previously referenced, the BTR process was ultimately reviewed by a Financial Analyst Ill, who
also did not question the aforementioned issues with the application. Some of the delay in the
process was due to the pandemic. However, the major delay was due to failed fire inspections
that were resolved and passed in April 2020.
Page 13 of 23
The codes that appear on the BTR are occupational codes from the schedule of taxes found in
City Code Section 102-379. The codes relate to a business tax category and the amount of tax.
The resort tax application that Mr. Thangavel completed and submitted by email to the Finance
Department on May 19, 2020, has "HOTEUMOTEL" marked as the type of business. However,
on the resort tax business account established for 1330 15" Street, the State license type is listed
as "Apartment" when in fact, the license issued by DBPR is "TRANSIENT APARTMENT." The
business type is listed as "APARTMENT" despite Mr. Thangavel's application identifying the kind
of business as "HOTEUMOTEL."
There is no explanation why the business type was listed as "Apartment" even though the
application that was received listed it as "HOTEUMOTEL" or evidence of communication with Mr.
Thangavel or the Permit Doctor employees to clarify the discrepancies. The summary of events
by Mr. Guzman previously referenced in this report states as follows:
Also, on May 19, 2020: A new Resort Tax (RTX) account was setup by the Finance
Department. Both the BTR and RTX accounts were created based on the Florida
State License (#TAP2330379), which is for an Apartment building.
The State of Florida issues transient apartment licenses and non-transient apartment licenses.
The difference is the minimum period of time the apartment is rented to guests. Transient
apartments are rented more than three times in a calendar year for periods less than 30 days or
1 calendar month, whichever is less. Non-transient apartments are rented for periods of at least
30 days or 1 calendar month, whichever is less. Listing the State license type on the resort tax
account as "Apartment" does not capture the actual type of license that the State issued to Mr.
Thangavel.
Current Certificate of Use and Business Tax Receipt Process
The method that was used to process and review Mr. Thangavel's combined Certificate of Use
(CU) and Business Tax Receipt (BTR) application was changed between June and August 2020.
The City moved to a predominately online application process which is accessed from the City's
website, called Citizen Self Service (CSS). The City continues to use the existing EnerGov system
for the review process. The application for a CU and BTR is no longer a single application. The
CU and BTR application processes are independent of each other.
As noted above, the first step in obtaining a license to do business is to obtain a Certificate of
Use. The issuance of a CU is under the authority of the Planning and Zoning Department. The
CU designation provides confirmation that the intended use at a specified location is consistent
with the City's Land Development Regulations.
The City's Information Technology Department provided the OIG assistance in replicating the
current application and review process for a CU and BTR. The application for a CU in the CSS
portal is a six-step process that includes (1) Locations, (2) Type, (3) Contacts, (4) More Info, (5)
Attachments, and (6) Review and Submittal. Throughout the process, there are required fields
that, if not completed, will not allow the applicant to move to the next step.
There are only two places in the process that allow the applicant to provide information about the
specific use of the business; the first is step two, which has a free text box that says "Description."
This text box is not (emphasis added) required, which means if one does not complete it, the
applicant can move to the next step. The second is step four which allows the applicant to select
a type of business from a mandatory checkbox list of eighteen types of businesses, and the last
check box is "None of the above." If the "none of the above box" is checked, it does not provide
Page 14 of 23
a free text box or any other information regarding other specific types of businesses. There is no
check box for lodging establishments. This step also includes instructive information about
Certificates of Use, Business Tax Receipts, and Conditional Uses.
Step five is for attachments, and it only requires a floor plan to be attached. Other documents
may be attached but are not required. The final step is where the applicant reviews the inputted
information and submits it for review. Once the application is submitted, a CU number is created,
and the screen shows in green that states the following:
Your license application was submitted successfully, No fees are due at this time;
we will review your application, and we will be in touch with you shortly.
The review process for the CU includes a Planning Department zoning approval and a Fire
inspection for each application. Once the Fire inspection approval is entered into the system, the
CU is automatically issued. The review of the process with the IT department showed a drop-
down list of available uses for the reviewer to select from, and there is a free-form text box for
notes. Ricardo Guzman of the Planning Department also provided the OIG with the list of specific
uses. It consists of a comprehensive list in alphabetical order, which includes multiple lodging
uses, including hotel, hostel, micro apartment units, transient non-residential, transient residential
(short-term rental), and bed and breakfast inn. Mr. Guzman advised the OIG that the selected
use, along with the notes, would appear on the issued Certificate of Use; for example, for a suite
hotel, the approved use would be "Hotel," and the note would identify "Suite Hotel." However,
such a list is unavailable for the applicant to choose from when applying for the CU.
A Certificate of Use is required to obtain a Business Tax Receipt, which is the license to operate
a business in the City. The BTR occupation code and business tax category are based on the CU
designation and the State license (if applicable). Therefore, it is of the utmost importance that the
party seeking to obtain a CU has access to a process that provides all the information needed to
apply for the specific use (emphasis added) that is being sought.
The application for a BTR in the CSS portal uses the same six-step process as the CU. It also
has required fields to be completed. In step two, "Type," there is a free text box for the business
description, which is not required, and a free text box for the BTR description, which is not
required. However, there is a link, "Select Industry Classification," that takes the applicant to a
comprehensive list of categories which includes "Accommodation & Food Services" along with
other broad industry categories. Once a category is selected, it opens a subcategory list that
replicates the occupational codes and business tax categories in the City Code. Step four, "More
Info," requires the Certificate of Use number to be entered. The only attachment that is required
is an executed lease or recorded warranty deed. Other attachments may be added. Once the
application is submitted, a BTR number is created, and the screen shows in green stating the
following:
Your license application was submitted successfully, No fees are due at this time;
we will review your application, and we will be in touch with you shortly.
The review process for the BTR follows the same process through the EnerGov system. The
disciplines that are assigned for the review are dependent on the type of BTR that is going to be
issued.
Page 15 of 23
Responses to the Draft Report and OIG Comment
In accordance with Section 2-256 (h) of the Code of Miami Beach, draft copies of this report were
provided to the affected individuals and entities covered in the report, including the City Manager,
City Attorney, Planning, Finance, and Building Directors, Chief of Police, Permit Doctor (permit
expediter), and the Complainant, Ananthan Thangavel for their discretionary written responses.
The OIG received responses from Mr. Thangavel, the City Planning Director, and the Chief
Financial Officer. These responses are incorporated herein as Appendices B, C, and D,
respectively. The OIG appreciates receiving these responses.
Response of Ananthan Thangavel, Complainant
Mr. Thangavel's responses are included in Appendix B of this report. Mr. Thangavel asserts that
the OIG obfuscated the clear fact that it was a City employee who, without his authorization,
altered the application by crossing out "short term rental" and inserting "Apt Bldg" on the CU/BTR
application in question. Mr. Thangavel states that this information was told to him during a
recorded video call with the OIG on May 10, 2023.
The OIG acknowledges that initially, during the video call, the OIG investigator did state that an
employee of the City made that change. However, the OIG investigator later revised that comment
when Mr. Thangavel sought a clarification:
Just to clarify, so the document that the Planning Director based his entire
explanation on in his staff report saying it was my evidence of intent to abandon
the use of my property, that document was altered by a City employee?
The OIG investigator responded: "I don't have 100% proof of that right now, because I don't know
who did that." At the time of the video call with Mr. Thangavel, the OIG had not spoken to anyone
in the Finance Department about the application in question.
On May 16, 2023, the OIG spoke with the Finance Department's Customer Service Manager,
Sasha Gonzalez. During that conversation, Ms. Gonzalez was asked if someone from the Finance
Department made the change to "Apt Bldg." She informed the OIG that no one would modify an
application that is received. She explained to the OIG that they receive the application, collect the
fee, and forward it through review and approval. Consequently, the OIG has been unable to
determine who made the change in question.
Mr. Thangavel has denied ever giving authorization to anyone to modify his original application,
the Permit Doctor employees deny making the change, and all City employees questioned have
similarly denied making the change. What is known is that the first page of the original application
was completely redone by Ms. Suraeva and that the application with the change in question was
uploaded into the system by a Finance Department staff member on December 27, 2019.
In his response, Mr. Thangavel also expressed his view that the alteration of a signed document
by a City employee "without express, written consent is the very definition of "malfeasance or
neglect." However, as stated above, the OIG does not have sufficient evidence to determine who
made the change in question.
Response of Thomas Mooney, Planning Director
Mr. Mooney's response is included in Appendix C of this report. His response provides information
to supplement and/or clarify issues raised in the draft report as it pertains to the 2019 CU/BTR
process and Mr. Thangavel. The response does not address the issues raised with the current
Page 16 of 23
process that is being used to apply for Certificates of Use and Business Tax Receipts. The issues
that were raised by Mr. Mooney in his response have been addressed in the relevant sections of
the report.
With respect to the Planning Department's review of the submitted CU/BTR application, Mr.
Mooney's response stated as follows:
It is important to point out that the application submitted by the property owner,
and uploaded to the system, was for an apartment building. City staff relies on the
accuracy of each applicant's submissions.
The OIG appreciates that City staff rely on the accuracy of each applicant's submission. However,
it is the reason for the lack of accuracy that concerns the OIG. In this instance, the application
was not submitted to the Finance Department by the property owner but by Ms. Jenny Suraeva,
an employee of the Permit Doctor (permit expediter) on behalf of the property owner, Mr.
Thangavel. Mr. Thangavel completed the first and second page of the application but did not
indicate anywhere on the document the specific type of business use for which he was applying.
In her interview with the OIG, Ms. Suraeva admitted to completing a new first page of the
application that differed from the original completed by Mr. Thangavel. On the new page that Ms.
Suraeva completed, she wrote, "short term rental" as the specific type of business. There were
no changes made to the second page of the application.
The application was then further modified, which, arguably, could be the most important
consideration in determining the designated use. The modified document showed that "short term
rental" had been crossed out and changed to "Apt Bldg" in what appears to be different
handwriting. Ms. Suraeva stated that she did not make the change, and Sasha Gonzalez, Finance
Department Customer Service Manager, informed the OIG that the change would not have been
made by anyone in the Finance Department as it is the Planning Department that determines the
use.
Mr. Thangavel has stated that he never authorized anyone to make any modifications to his
original application. So, the modified application with different handwriting than the original second
page and the specific type of business changed from "short term rental" to "Apt Bldg" in different
handwriting was accepted, without question, and uploaded by the Finance Department to be
reviewed and relied upon for the issuance of a Certificate of Use and a Business Tax Receipt.
The normal course of business for modifications to a document would, at a minimum, require that
the person who modified the document initial or sign and date the change or that a new application
be completed. Neither of these was done, which has resulted in confusion over who was
responsible for the change with possible legal consequences.
Regarding the planning review, Mr. Mooney's response stated the following:
The subject property is zoned RM-1 (Residential, Multi-Family Low Intensity) and
this zoning district expressly permits apartment buildings as a permitted use. Since
this is a permitted use, and the previously issued permit for suite hotel confirmed
that the building met the minimum unit size requirements for an apartment unit,
there was no reason for a Planning reviewer to inquire further. In short, if a
proposed use is permitted within a zoning district, the Planning reviewer does not
initiate an inquiry as to why the property owner desires to license a permitted use.
Page 17 of 23
The OIG would agree that in the cases in which the application was complete and with no strike-
throughs or modifications, no further inquiry would be necessary. However, in this instance, the
reviewer had an application in which the specific type of business, "short term rental" had been
struck through, and "Apt Bldg" had been written in what appears to be different handwriting. As
noted above, there were no initials, signature, or date for the change. Moreover, the previous
CU/BTR, to which the reviewer had access, was for a suite hotel which is a form of short-term
rental. This fact warranted further inquiry prior to an official determination on the permitted use.
Although short-term rentals were not permitted within the zoning district, Mr. Mooney stated the
following in his response:
It is important to note that had the CUIBTR application for the short-term rental of
the units in the building been submitted as part of the application approved on
May 19, 2020, that CU/BTR application would have been denied by Planning and
the applicant, at that point, could have potentially modified the application to a
suite hotel, which was a permitted use until August of 2020.
Mr. Mooney's response makes note that although short-term rentals are not defined in Section
114-1 {the definitions section of the Land Development Regulations (LDRs) of the City Code of
Miami Beach), they are defined under Section 142-1111 of the LDRs. The definitions section,
however, is the first section of the LDRs and is the logical section for the term to be defined.
Indeed, it is Section 114-1 where the definitions of suite hotels, apartment hotels, hostels, and
hotels are located. Moreover, Section 142-1105 details the regulations related to suite hotels,
apartment hotels, hostels, and hotels, referencing the definitions found in Section 114-1, but is
silent regarding short term rentals.
Response of Jason Greene, Chief Financial Officer
Mr. Greene's response is included in Appendix D of this report. Mr. Greene concurs with the OIG
that there was no malfeasance or neglect by City employees. He asserts that any
miscommunication, misunderstanding, or misinterpretation was between Mr. Thangavel and his
permit runner, the Permit Doctor and that Mr. Thangavel relied on the Permit Doctor to handle his
local Business Tax Receipt application.
In his response, Mr. Greene stated the following:
The applicant and their permit runner, submitted a Local Business Tax Receipt
application with a different type business category than the previous owner. The
applicant and their permit runner, also submitted an application with a different
type of State license than the previous owner of the property. The applicant was
given the Local Business Tax Receipt they applied for.
This statement by Mr. Greene is accurate; however, in 2019, when the application was submitted,
it was an application for a Certificate of Use (CU) as well as an application for a Business Tax
Receipt {BTR). The Finance Department was the starting point for an applicant to obtain both a
CU and a BTR in a single application. In this instance, the Finance Department accepted a two-
page application in which the handwriting on the first page was different from the second page,
and the specific type of business, "short term rental," was struck through and replaced with "Apt
Bldg." That modification to an official application was not initialed, signed, or dated. Nevertheless,
the application was accepted without question by the Finance Department and uploaded to be
relied upon by the Planning Department for the determination of its permitted use. It was this
altered application along with the State of Florida-issued license that the Finance Department
relied upon to issue the BTR.
Page 18 of 23
As detailed in this report, the OIG identified that the State of Florida mistakenly issued the previous
owner a license for a hotel. As included in Appendix A of this report, Florida Statues Section
509.242 provides the following definition of a hotel:
any public lodging establishment containing sleeping room accommodations for
25 or more guests and providing the services generally provided by a hotel and
recognized as a hotel in the community in which it is situated or by the industry.
The business located at 1330 15 Street does not meet this definition. The appropriate State
license should have been for a non-transient apartment which is defined as, "a building or complex
of buildings in which 75 percent or more of the units are available for rent to non-transient tenants."
Mr. Thangavel was appropriately issued a non-transient apartment license by the State of Florida,
which based on the State definition, would allow him to operate a suite hotel or short-term rentals
in the City of Miami Beach.
Mr. Greene's response, regarding quality control and supervisory review, points out the following:
the initial intake of an application is processed by one employee, and the final
issuance of the BTR is not released until a supervisor has reviewed the
application for thoroughness. A review of the EnerGov system demonstrates that
this particular BTR application was processed by a Financial Analyst I and
subsequently reviewed by a Financial Analyst II, and ultimately reviewed by a
Financial Analyst Ill before being issued.
The OIG has addressed this observation within the sections of the report that address the Finance
Department.
Conclusion and Recommendations
The Miami Beach Office of the Inspector General (OIG) has concluded its investigation and
process review into allegations that (1) City of Miami Beach employees may have engaged in
malfeasance or negligence with respect to the issuance of a Certificate of Use (CU) /Business
Tax Receipt (BTR) for the property located at 1330 15" Street, Miami Beach and owned by 1330
15" Street, LLC (Ananthan Thangavel); (2) an employee of permit expediter, Permit Doctor,
forged the CU/BTR application that was submitted to the City and; (3) a City of Miami Beach
Planning and Zoning employee instructed the Miami Beach Police Detective looking into the
forgery allegation not to investigate the matter.
Allegations two and three were unsubstantiated. The allegation of forgery was reported to the
Miami Beach Police Department (MBPD) by Mr. Thangavel. MBPD determined that the matter
was civil in nature, and did not proceed with a criminal investigation, a decision with which the
OIG agrees based on this review. Regarding the allegation that the MBPD Detective assigned to
the complaint was improperly instructed by a City staff member not to investigate the matter, both
the Detective and the City employee involved denied that any such instruction occurred, and the
OIG found no evidence in this review of any such misconduct.
While the OIG's investigation of Allegation (1) concluded that there was no evidence of
malfeasance or negligence on the part of City employees with respect to the issuance of the
CU/BTR, it did find some aspects of the City's procedures to be problematic, which led to a
Page 19 of 23
thorough review of the process. In conducting this review, the OIG appreciates the cooperation
and assistance of the Planning, Finance, Building, and Information Technology Department staff
and specifically, Thomas Mooney, Ricardo Guzman, Sasha Gonzalez, Gabi Chamoun, Ozzy
Macias, and Wingrove Duverney.
During the review, the OIG found that miscommunication, misunderstanding, and/or a
misinterpretation of the various meanings of accommodation establishment terminologies
throughout the process by Mr. Thangavel and the Permit Doctor employees, the delay in time
caused by the pandemic, and insufficient quality controls on the part of the City resulted in Mr.
Thangavel's being issued a CU/BTR for "APARTMENT ROOMS" (non-transient) (Exhibit 4)
instead of "HOTELS (SMOKE DETECTOR)" (Exhibit 2), the Certificate of Use designation that
allowed the previous owner to operate as a Suite Hotel.
The OIG found that early in the process, in September 2019, Mr. Thangavel's attorney was
provided a zoning determination letter from Planning Director Thomas Mooney that advised them
that "suite hotels" were an authorized use in the location of Mr. Thangavel's building. It did not
specifically state that "short-term rentals" were prohibited in the area. Although suite hotels are a
type of short-term vacation rental, they are considered different from short-term rentals in the City
Code. Suite Hotels are defined in the definitions section of the Land Development Regulations of
the City Code. However, "Short-term rentals" are not. Throughout his pursuit of a license to
operate the business that he purchased as a suite hotel, neither Mr. Thangavel, nor his hired
expediter, ever used the term "suite hotel" in their effort to obtain a business license.
The OIG found that it was Permit Doctor employee Damien Gallo Jr's understanding that Mr.
Thangavel wished to pursue a license for short-term rentals. Mr. Gallo Jr. and Ms. Suraeva were
unaware of the differences between a suite hotel and a short-term rental. In fact, Mr. Gallo Jr.
stated that he used it interchangeably and acknowledged that it might have been an error to do
so. Mr. Gallo Jr. and Ms. Suraeva informed the OIG that they did not recall ever assisting in the
licensing of a suite hotel. It wasn't until the individual short-term rental applications for each of Mr.
Thangavel's units were submitted electronically on September 24, 2021, by Mr. Gallo Jr. and
denied by the City that they realized that short-term rentals were not authorized at the building's
location. By that time, suite hotels were also not authorized.
The OIG found that the City Finance Department accepted and uploaded an application that had
been altered into the EnerGov system that would be relied upon for the issuance of the CU/BTR.
The writing on the first page was different from the writing on the second page. "Short-term rental"
had been lined through, and "APT Bldg" had been added in what appears to be different
handwriting, and the form version of page one was different from the form version of page two.
Although the Finance Department had two supervisory reviews of the application and associated
documents throughout the process, there is no evidence that the validity of the application was
ever questioned.
The OIG found that, during the planning review for the Certificate of Use, the application that was
submitted in December 2019 (Exhibit 6), as well as the application that was originally completed
by Mr. Thangavel and not submitted (Exhibit 5), was for a "Change of Owner." Neither application
indicated a "Change of Use." The previous use was for "HOTELS." The Planning Department
reviewer had access to the previous BTR and the application, and Mr. Guzman stated in the
previously cited email that there were no documents requested or provided to support the change
of use, yet the Planning Department approved a change of use from "HOTELS" to "APARTMENT
ROOMS" without any communication with Mr. Thangavel or Permit Doctor employees questioning
the change of use. The application itself states the following:
Page 20 of 23
A Change of Use may generate additional building and fire code requirements as
applied to new construction.
There is no evidence, no internal notes, or any other documentation indicating that additional
building and fire code requirements were or were not needed for the change of use.
The OIG found that the multiple forms required by the City indicated different types of use. The
CU/BTR application that was submitted had short-term rental lined through and "Apt Bldg" written
below it (Exhibit 6). The required smoke detectors inspection/test report form indicates the type
of occupancy as "Short-term rental" (Exhibit 8), and the resort tax registration form indicates
"Hotel/Motel" (Exhibit 9). Two of these forms are submitted to the Finance Department, and the
other is submitted to the Fire Prevention Division of the Fire Department at different times in the
process. There is no evidence of a final supervisory or quality control review that examines all of
the required documentation for consistency.
The OIG found that the City relied on the State license to establish the BTR and Resort Tax
accounts. The summary of events provided by Mr. Guzman includes the following:
Also, on May 19, 2020: A new Resort Tax (RTX) account was setup by the Finance
Department. Both BTR and RTX accounts were created based on the Florida
State License (#TAP2330379), which is for an Apartment Building.
The State license (Exhibit 10) was issued for a "Transient Apartment," which, as defined by the
State of Florida, allows for short-term rental and suite hotels. For a residential apartment building
which is the CU/BTR that the City ultimately issued to Mr. Thangavel, the State of Florida would
have issued a "Non Transient Apartment" license.
The miscommunication and misunderstanding of the difference between a suite hotel and a short-
term rental by Mr. Thangavel and the Permit Doctor employees; the reliance by the City on the
terminology of the State license, which contains definitions that differ from the City's; and a lack
of sufficient quality controls on the part of the City, the most significant example being the
acceptance and reliance of an obviously altered application with strikethroughs and additions that
were not initialed, signed or dated. In fact, it was this altered application that set forth the domino
effect that resulted in confusion that led to the granting of a different license than what may have
been intended. As a result of these actions, Mr. Thangavel is still pursuing an appeal for
reconsideration of this issue through the City's Board of Adjustment.
As part of this review, the OIG, knowing that the process that was used to accept, review and
issue Mr. Thangavel's CU/BTR is no longer in effect, reviewed the current CU and BTR
processes. The OIG found that the current application process for customers in the Citizen Self-
Service portal could still lead to confusion and the potential for Certificates of Use being issued
for a use that is not intended.
The OIG found that when a customer first accesses the CU application portal or the BTR
application portal, there are no instructions or information for completing the application, which
could lead to confusion, misunderstanding of the requirements, and unintended consequences.
The first place that any instructive information or definitions appear in the CU application process
is in step four of the six-step process. The only place to specifically describe the type of business
is in a text box that is not required to be completed. This text box appears in step two, prior to a
Page 21 of 23
mandatory checkbox that allows the applicant to select from a list of eighteen types of businesses.
If the type of business a customer is looking for is not there; there is only an option of checking
"none of the above."
The OIG found that, although the BTR application portal did not have instructions or information
when the application process is first accessed, it did have a more robust selection of the types of
businesses available to the customer as detailed in this report. The selections mirrored the
business tax categories that are represented in the City Code.
A Certificate of Use is required by the City of Miami Beach to obtain a Business Tax Receipt,
which is the license to operate a business in the City. The BTR occupation code and business tax
category are based on the CU designation and the State license (if applicable). It is of the utmost
importance that any party seeking to obtain a CU and BTR to do business in the City have access
to a process that is both clear and informative, providing all the information needed to apply for
the specific use (emphasis added) that is being sought to conduct such business and that the
possible consequence legal challenge over the result be minimized. To assist in this process, the
OIG offers the following recommendations
1. The term "short-term rental" be defined in Section 114-1, which is the definitions section
of the Land Development Regulations, should be consistent with the definitions of other
lodging accommodation methods, including suite hotels, apartment hotels, hostels, bed
and breakfast, and hotels.
2. The initial screen in the Citizen Self-Service Portal for the Certificate of Use and the
Business Tax Receipt application should provide definitions and instructions for
completing the process, including any important information that would result in the denial
of the application.
3. It should be mandatory that the text box in the Citizen Self-Service Portal for the Certificate
of Use application, which instructs the applicant to describe the type of business to be
conducted, be completed prior to application moving forward in the process. Currently, the
application may move forward in the process without providing a description of the type of
business.
4. As the determination of the specific use is the single most important aspect of the issuance
of a Certificate of Use and is required and relied upon to obtain a Business Tax Receipt,
the selection of available uses should follow the same process as that of the BTR
application, with drop-down selection boxes of available uses and sub uses. The back end
of the portal that is available to the Planning staff includes a drop-down selection of several
uses. That option should be made available to the applicant.
5. Although there did exist some level of quality control in the process reviewed, there should
be a protocol for the acceptance of documents that appear to be altered.
Section 2-256 (d) (3) of the City Code confers upon the Office of the Inspector General the power
to require reports from the city manager, city departments, city agencies, boards, and committees,
and city officers and employees, regarding any matter within the jurisdiction of the inspector
general. The OIG requests that the City provide a status report to the OIG within sixty (60) days
of the receipt of this report on the implementation of any of the OIG recommendations.
Page 22 of 23
2z2
Dylan Hughes, Investigator
CC: Alina Hudak, City Manager
Steven Rothstein, Deputy City Attorney
Thomas Mooney, Planning Director
Jason Greene, Chief Financial Officer
Rick Clements, Chief of Police
Ana Salgueiro, Building Director, Building Official
Ananthan Thangavel, 1330 15" Street, LLC
Damian Gallo Jr., Permit Doctor
Eugenia (Jenny) Suraeva, Permit Doctor
OFFICE OF THE INSPECTOR GENERAL, City of Miami Beach
1130 Washington Avenue, 6 Floor, Miami Beach, FL 33139
Tel: 305.673.7020 • Hotline: 786.897.1111
Email: CilyofMiamiBeachQIG@miamibeachfl.gov
Website: www.mbinspectorgeneral.com
Page 23 of 23
OIG
APPENDIX
“A”
RELEVANT GOVERNING
AUTHORITIES
Relevant Governing Authorities
Florida Statutes Section 509.013 Definitions.
(4) (a) “Public lodging establishment” includes a transient public lodging establishment as defined in
subparagraph 1. and a nontransient public lodging establishment as defined in subparagraph 2.
1. “Transient public lodging establishment” means any unit, group of units, dwelling, building, or group
of buildings within a single complex of buildings which is rented to guests more than three times in a
calendar year for periods of less than 30 days or 1 calendar month, whichever is less, or which is
advertised or held out to the public as a place regularly rented to guests.
2. “Nontransient public lodging establishment” means any unit, group of units, dwelling, building, or
group of buildings within a single complex of buildings which is rented to guests for periods of at least 30
days or 1 calendar month, whichever is less, or which is advertised or held out to the public as a place
regularly rented to guests for periods of at least 30 days or 1 calendar month.
Florida Statutes Section 509.241 Licenses required; exceptions.
(1) Licenses; Annual Renewals. Each public lodging establishment and public food service establishment
shall obtain a license from the division…..
(2) Application For License. Each person who plans to open a public lodging establishment or a public
food service establishment shall apply for and receive a license from the division prior to the
commencement of operation….
Florida Statutes Section 509.242 Public lodging establishments; classifications.
(1) A public lodging establishment shall be classified as a hotel, motel, nontransient apartment, transient
apartment, bed and breakfast inn, timeshare project, or vacation rental if the establishment satisfies the
following criteria:
(a) Hotel.—A hotel is any public lodging establishment containing sleeping room accommodations for 25
or more guests and providing the services generally provided by a hotel and recognized as a hotel in the
community in which it is situated or by the industry.
(d) Nontransient apartment.—A nontransient apartment is a building or complex of buildings in which
75 percent or more of the units are available for rent to nontransient tenants.
(e) Transient apartment.—A transient apartment is a building or complex of buildings in which more
than 25 percent of the units are advertised or held out to the public as available for transient occupancy.
Miami Beach Code Subpart B- Land Development Regulations (LDR)
LDR Section 114-1 Definitions.
Apartment building means a building with or without resident supervision occupied or intended to be
occupied by more than two families living separately with separate cooking facilities in each unit.
Apartment unit means a room, or group of rooms, occupied or intended to be occupied as separate
living quarters by one family and containing independent cooking and sleeping facilities. (Term includes
condominium.)
Certificate of use means a document issued by the city manager or designee allowing the use of a
building and certifying that the use is in compliance with all applicable city codes, regulations, and
ordinances.
Hotel means a building occupied or intended to be occupied by transient residents, with all residents
occupying hotel units and where ingress or egress may or may not be through a common lobby or office
that is supervised by a person in charge at all times.
Hotel unit means a room, or group of rooms, each unit containing a separate bathroom facility, with
ingress or egress which may or may not be through a common lobby, intended for rental to transients
on a day-to-day, week-to-week, or month-to-month basis, not intended for use or used as a permanent
dwelling and without cooking facilities.
Suite hotel unit and suite hotel means a room, or group of rooms, each containing separate bathroom
and full cooking facilities, with ingress and egress which may or may not be through a common lobby,
intended for rental to transients on a day-to-day, week-to-week, or month-to-month basis, not intended
for use or used as a permanent dwelling.
Note by OIG: Short-term rental of any type of dwelling is not defined in this section.
LDR Section 142-151. – Purpose.
The RM-1 residential multifamily, low density district is designed for low intensity, low rise, single-family
and multiple-family residences.
LDR Section 142-152. - Main permitted and prohibited uses.
(a)The main permitted uses in the RM-1 residential multifamily, low density district are:
(1)Single-family detached dwelling;
(2)Townhomes;
(3)Apartments;
(4)Apartment hotels, hotels, and suite hotels for properties fronting Harding Avenue or Collins Avenue,
from the city line on the north, to 73rd Street on the south (pursuant to section 142-1105 of this
chapter);
(5)Bed and breakfast inn (pursuant to article V, division 7 of this chapter); and
(6)Apartment hotels, hotels, and suite hotels for properties abutting Lincoln Lane South, between Drexel
Avenue and Lenox Avenue, subject to the following regulations:
(i)The lot width of the property shall not exceed 100 feet;
(ii)The lobby from which the property is accessed shall be located within a building fronting Lincoln
Road, which is located directly across Lincoln Lane South from the RM-1 property;
(iii)The hotel shall be operated by a single operator; and
(iv)No accessory uses associated with a hotel shall be located or permitted within the RM-1 district.
LDR Section 142-1105 - Suites hotel, apartment hotel, hostel, and hotel. Relevant Sections:
(a) Suite hotel units and suite hotels, as defined in section 114-1 of the land development regulations,
shall conform with the following regulations:
(1) When a hotel unit contains cooking facilities it shall be considered as a suite hotel unit. Suite hotel
units may have full cooking facilities, provided the unit is at least 550 square feet in size.
(3) A minimum of ten percent of the total gross area shall be maintained as common area, however this
requirement shall not apply to historic district suites hotels. This provision shall not be waived or
affected through the variance procedure.
(4) The building shall contain a registration desk and a lobby. Any transient guest or occupant for a suite
hotel unit must register at the registration desk. Those transient guest(s) or occupant(s) are prohibited
from accessing the suite hotel unit without registration.
(8) Suite hotels shall be prohibited in all zoning districts and overlay districts that do not list suite hotels
as a permitted or conditional use.
LDR Section 142-1111 – Short-term rental of apartment units or townhomes.
Relevant Sections:
(a) Limitations and prohibitions.
(1) Unless a specific exemption applies below, the rental of apartment or townhome residential
properties in districts zoned RM-1, RM-PRD, RM-PRD-2, RPS-1 and RPS-2, CD-1, RO, RO-3 or TH for
periods of less than six months and one day is not a permitted use in such districts.
(2) Any advertising or advertisement that promotes the occupancy or use of the residential property for
the purpose of holding commercial parties, events, assemblies, gatherings, or the occupancy of a
residence for less than six months and one day, as provided herein, or use of the residential premises in
violation of this section.
Miami Beach Code Subpart A- General Ordinances Article V. Local Business Tax
Section 102-356- Construction of article; definitions.
Relevant Sections:
Business means every trade, occupation, profession or other manner of revenue-producing activity
regardless of whether a profit is actually made.
Business tax means the fees charged and the method by which the city grants the privilege of engaging
in or managing any business, profession, or occupation within the city's jurisdiction.
OIG
APPENDIX
“B”
RESPONSE OF ANANTHAN THANGAVEL,
COMPLAINANT, TO THE OIG DRAFT REPORT
From:
To:
Cc:
Subject:
Date:
Attachments:
Ananthan Ihangavel
Alonso, Elisa; Hudson, Phillip M.
Centorino, Joseph; Hughes, Dylan
Re: Cover Letter and OIG Draft Reports: Review of Complaint and Process Regarding Certificate of Use and BTR
at 1330 15th Street
Friday, July 14, 2023 1:56:54 PM
20191118-TR Aplication-Correct.pdf
[ THIS MESSAGE COMES FROM AN EXTERNAL EMAIL SE CAUTION WHEN
REPLY IG AND OPENING LINKS OR ATTACHMENTS [
Office of Inspector General,
Thank you for the draft report. In response to the draft report, I would like to request the
following: I would like the report to make clear that Ms. Suraeva openly admitted to altering
the BTR application document that I submitted to her (attached here), and that the document
was then further altered by a City of Miami Beach employee. Furthermore, I have sworn
under oath and am prepared to further swear to the fact that I never authorized any change to
this document whatsoever, and that all alterations were done without my consent.
Additionally, we were wondering if the IG report could be finalized and made official before
July 25th, as the City Attorney's office has requested that the report be made final before they
re-engage discussing the matter at hand in our Board of Adjustment case, and they are
requesting a large invoice to be paid (-$4600) by July 25th. If we could finalize the report
before that time, it would be a great help towards putting this matter to rest without further
harm to me.
Thank you, please let me know.
From:
To:
Cc:
Subject:
Date:
Ananthan Ihangavel
Hughes, Dylan
Alonso, Elisa; Hudson, Philip M.; Centorino, Joseph
Re: Cover Letter and OIG Draft Reports: Review of Complaint and Process Regarding Certificate of Use and BTR
at 1330 15th Street
Tuesday, August 1, 2023 3:05:18 PM
[ THIS MESSAGE COMES FROM AN EXTERNAL EMAIL - USE CAUTION WHEN
REPLYING AND OPENING LINKS OR ATTACHMENTS ]
In further response to the IG report, I would like to comment the following:
While the Inspector General's report did uncover the source of the first unauthorized revision
of the BTR application which this matter centers upon (Jenny Suraeva of The Permit Doctor),
the report obfuscates a clear and important fact that was stated to me on a recorded video call
with the IG office dated 5/10/23. The second unauthorized revision of this document, which
consisted of crossing out Short-Term Rentals and writing Apt. Building, was done by a City of
Miami Beach employee.
Furthermore, the I G's assertion that a City of Miami Beach employee can alter a signed
document, and that this behavior is not considered "malfeasance or neglect by City
employees" is utterly preposterous. Altering another person's signed document without
express, written consent is the very definition of "malfeasance or neglect".
Finally, for any party in this matter to claim they do not have records going back over 2 years
is ridiculous. The construction time line from design/permitting to Certificate of Occupancy of
any construction project of consequence is more than 2 years. The Permit Doctor would not
be able to perform its very namesake if they in fact did not keep documents going back more
than 2 years.
In fact, The Permit Doctor and the City of Miami Beach have no evidence that I authorized
these changes to the BTR application because no such evidence exists, because I never
authorized any change whatsoever to this document.
OIG
APPENDIX
“C”
RESPONSE OF THOMAS MOONEY, PLANNING
DIRECTOR, TO THE OIG DRAFT REPORT
From:
To:
Cc:
Subject:
Date:
Attachments:
Importance:
Mooney, Thomas
Alonso, Elisa
Hudak, Alina; Rothstein, Steven; Greene, Jason; Clements. Rick; Salgueiro, Ana; Bain,_ Tiffany; Williams, Rickelle;
Centorino, Joseph; Hughes, Dylan
Planning Department Response: OIG Review of Complaint and Process Regarding Certificate of Use and BTR at
1330 15th Street
Friday, July 28, 2023 12:24:34 PM
Review of Complaint and Process Regarding Certificate of. Use and BIR at 1330 15th Street.pdf
Cover Letters- City.pdf
High
Good Afternoon Elisa
This email shall serve as the Planning Department's Response to the Draft OIG Report, dated June
16, 2023, relating to the Review of Complaint and Process Regarding Issuance of Certificate of Use
and Business Tax Receipt at 1330 15th Street ("Draft Report").
As a threshold matter, the Draft Report concerns issues that are also the subject of an administrative
appeal currently pending before the Board of Adjustment. Pursuant to Article I, Section 2 of the
Related Special Acts, and Sections 118-9 and 118-397 of the Land Development Regulations, the
Board of Adjustment has the exclusive jurisdiction to decide appeals from formal determinations of
the Planning Director.
On February 22, 2023, the owner of the property at 1330 15th Street appealed the denial of a
Business Tax Receipt on the basis that, pursuant to the Land Development Regulations, short-term
rentals are not permitted on the subject property. On May 5, 2023, and following argument and
testimony from the property owner, Planning Director, and nearby residents, the Board of
Adjustment denied the appeal and affirmed the decision of the Planning Director.
On June 2, 2023, the Board of Adjustment adopted a motion to reconsider its May 5th decision.
Pursuant to that motion, the appeal will be re-noticed for the September 8, 2023 Board of
Adjustment meeting. At that time, the Board will take additional testimony, and decide whether to
affirm or reverse its original decision.
Notwithstanding the appeal pending before the Board of Adjustment, which will make a final
determination as to whether the previous use of suite hotel may be reintroduced, the Planning
Department wishes to provide the following information to supplement and/or clarify issues raised
in the Draft Report.
1. Response to the Summary, in the Draft Report of events between May 19, 2020 and September
24, 2021
A CU/BTR was issued to the property owner (Mr. Thangavel) on May 19, 2020 for non-transient
apartment rooms. This CU/BTR was renewed on December 20, 2020 and remained active until
September 30, 2021.
Notwithstanding the fact that a CU/BTR was issued for the property, on page 6 of the Draft Report,
Mr. Gallo Jr. (who, at the time, was the owner's permit expediter) is described as indicating that the
process to obtain a CU/BTR was never completed. It appears that Mr. Gallo is referring to the
CU/BTR that would otherwise be required for the short-term rental of the eight units in the building;
however, this is not clear. On page 8 of the Draft Report, the employees of the Permit Doctor
acknowledge that each unit proposed to be used for short-term rentals must obtain a separate
CU/BTR, but such applications were never submitted by the Permit Doctor to the City until
September 24, 2021.
There is no explanation as to why an application for the short-term rental of the units was not made
until September 24, 2021. The previous use of suite hotel at the property became prohibited in
August of 2020 (pursuant to Ordinance No. 2020-4364, which removed "suite hotels" as an
allowable use in the West Avenue Bayfront Overlay District}. It is important to note that had the
CU/BTR application for the short-term rental of the units in the building been submitted as part of
the application approved on May 19, 2020, that CU/BTR application would have been denied by
Planning and the applicant, at that point, could have potentially modified the application to a suite
hotel, which was a permitted use until August of 2020.
2. Request of the Property Owner for the Short-Term Rental of all Eight (8) units
On page 9 of the Draft Report, it is noted that one of the documents uploaded by the Permit Doctor
(the permit expediter} on September 24, 2021 for the short-term rental CU/BTR application was a
June 15, 2020 letter from the property owner indicating his intent to apply for a short-term rental
BTR for all eight units in the building. The Draft Report further notes that this letter was not part of
the documentation received by the City on December 27, 2019 and therefore was not considered
part of the process.
First, it is not possible for a document that was signed on June 15, 2020 to have been part of an
application submitted 6 months earlier, on December 27, 2019. Second, there is no explanation as to
why this correspondence from June 15, 2020 was not included in a CU/BTR application until
September 24, 2021. Again, if a CU/BTR application for short-term rentals had been submitted prior
to August of 2020, although it would have been denied by Planning (because short-term rentals have
been prohibited in this district since 2010}, it is likely that the applicant would have questioned why
the application was denied and been advised that Suite Hotel was still a permitted use and the
application could have been modified to reflect a suite hotel.
3. Closing of Previous BIR for Suite Hotel Use
On page 11 of the Draft Report, it is noted that as part of December 27, 2019 CU/BTR application,
the prior CU/BTR for a suite hotel on the property was uploaded. The report further indicates that
this prior BTR was issued to the previous property owner on September 27, 2019 and expired on
September 30, 2020. The report, however, does not recognize that this previous BTR (and
corresponding resort tax account} was closed, in writing, by the previous property owner, on
November 27, 2019. As such, the application submitted on December 27, 2019 was considered a
new CU/BTR application.
4. Planning Review of CU/BIR Application
On page 12 of the Draft Report, under "Planning Review," as it pertains to the review of the
December 27, 2019 CU/BTR application, the Planning comments note that the application is for a
residential apartment building (8 units). It is further noted in the report that there is no explanation
of how that determination was made.
It is important to point out that the application submitted by the property owner, and uploaded to
the system, was for an apartment building. City staff relies on the accuracy of each applicant's
submissions. The subject property is zoned RM-1 (Residential, Multi-Family Low Intensity) and this
zoning district expressly permits apartment buildings as a permitted use. Since this is a permitted
use, and the previously issued permit for suite hotel confirmed that the building met the minimum
unit size requirements for an apartment unit, there was no reason for a Planning reviewer to inquire
further. In short, if a proposed use is permitted within a zoning district, the Planning reviewer does
not initiate an inquiry as to why the property owner desires to license a permitted use.
Also, whether the 'change of use' box was checked or not had no impact on this CU/BTR application
in terms of zoning review, as apartment building is a permitted use in the underlying RM-1 zoning
district and the previous use (suite hotel) met the applicable unit size and kitchen requirements for
an apartment unit.
5. Definition of Short-Term Rental (SIR)
On page 17 of the Draft Report, it is noted that suite hotels are defined in the definitions section of
the Land Development Regulations ("LDRs"), but that short-term rentals are not. However, short-
term rentals are defined under Sec. 142-1111 of the LDRs, as "the rental of apartment or townhome
residential properties in districts zoned RM-1, RM-PRD, RM-PRD-2, RPS-1 and RPS-2, CD-1, RO, RO-3
or TH for periods of less than six months and one day."
Thomas R. Mooney, AICP
Planning Director
Planning Deportment
700 Convention Center Drive- 37d Foor, Miami Beach, FL 33139
Tel: 305-673-7000 x6191 / 1money@miamibeach fl,gov
www.miamibeachfl.gov
It's easy being Green! Please consider our environment before printing this email.
OIG
APPENDIX
“D”
RESPONSE OF JASON GREENE, CHIEF FINANCIAL
OFFICER, TO THE OIG DRAFT REPORT
Hughes. Pyan
From:
Sent:
To:
Cc:
Subject:
Greene, Jason
Monday, July 31, 2023 9:51 AM
Hughes, Dylan
Centorino, Joseph; Hudak, Alina; Bain, Tiffany; Rothstein, Steven; Clements, Rick;
Salgueiro, Ana; Mooney, Thomas; Carpenter, Eric; Marquez, Manny
RE: Cover Letters and OIG Draft Reports: Review of Complaint and Process Regarding
Certificate of Use and BTR at 1330 15th Street
Dylan,
Please find below response from Finance.
Thanks,
Business Tax Section Response:
The Business Tax Section of the Finance Department concurs with the Office of the Inspector General (OIG)
with respect to the review and process regarding the issuance of the Certificate of Use and Business Tax
Receipt for the property located at 1330 15" Street, "there was no malfeasance or neglect by City employees."
Allegation 1;
City of Miami Beach employees may have engaged in malfeasance and/or negligence with respect to
the issuance of a Certificate of Use (CU) /Business Tax Receipt (BTR} for the property.
Response:
The Business Tax Section concurs with the OIG Conclusion regarding the allegation, "the issuance of the
CU/BTR to Mr. Thangavel, was thoroughly reviewed by the OIG, which concluded that there was no
malfeasance or neglect by City employees."
The property owner hired a permit runner to process their application. If there was any miscommunication,
misunderstanding and/or misinterpretation, it was between the applicant, Mr. Thangavel, and his permit runner,
the Permit Doctor, as stated in page 17 of the OIG's report, "during the review, the OIG found that
miscommunication, misunderstanding, and/or a misinterpretation of the various meanings of accommodation
establishment terminologies throughout the process by Mr. Thangavel and the Permit Doctor employees." The
applicant relied on his permit runner to handle his Local Business Tax Receipt application.
The applicant and their permit runner, submitted a Local Business Tax Receipt application with a different type
business category than the previous owner. The applicant and their permit runner, also submitted an
application with a different type of State license than the previous owner of the property. The applicant was
given the Local Business Tax Receipt they applied for.
The City's Board of Adjustment, at their May 5", 2023 meeting, denied the applicants appeal to reinstate a
non-conforming suite hotel use on the property.
MIAMIBEACH
Jason D. Greene, CGFO, CFE, Chief Financial Officer
City of Miami Beach
1700 Convention Center Drive, Miami Beach, FL 33139
1
OIG
EXHIBIT 1
NOTUS LLC CU/BTR
APPLICATION
OIG
EXHIBIT 2
NOTUS LLC CU/BTR
OIG
EXHIBIT 3
NOTUS LLC
CO
OIG
EXHIBIT 4
1330 13TH ST LLC CU/BTR
ADDRESS:
1700 Convention Center Drive
Miami Beach, Florida 33139-1819
TRADE NAME:
IN CARE OF:
1330 15TH STREET LLC
1330 15 St
MIAMI BEACH, FL -331392249
LICENSE NUMBER:
Beginning:
Expires:
Parcel No:
BTR008501-12-2019
09/30/2020
0232330160200
CITY OF MIAMI BEACH
CERTIFICATE OF USE, ANNUAL FIRE FEE, AND BUSINESS TAX RECEIPT
05/19/2020DBA:
Code Business Type
95000900 APARTMENT ROOMS
95700000 Apartment buildings (rental), not including kitchens
and bathrooms
Apartment Bldgs Rental: # Units 8
TRADE ADDRESS:1330 15 St
A penalty is imposed for failure to keep this Business Tax Receipt
exhibited conspicuously at your place of business.
A Business Tax Receipt issued under this article does not waive or
supersede other City laws, does not constitute City approval of a
particular business activity and does not excuse the licensee from all
other laws applicable to the licensee's business.
This Receipt may be transferred:
A. Within 30 days of a bonafide sale, otherwise a complete annual
payment is due.
B. To another location within the City if proper approvals and the
Additional Information
Storage Locations
FROM:
1330 15TH STREET LLC
1330 15 St
MIAMI BEACH, FL -331392249
PRESORTED
FIRST CLASS
U.S. POSTAGE
PAID
MIAMI BEACH, FL
PERMIT No 1525
CITY OF MIAMI BEACH
1700 CONVENTION CENTER DRIVE
MIAMI BEACH, FL 33139-1819
OIG
EXHIBIT 5
1330 15TH ST LLC ORIGINAL
CU/BTR APPLICATION
OIG
EXHIBIT 6
1330 15TH ST LLC CHANGED
CU/BTR APPLICATION
OIG
EXHIBIT 7
1330 15TH ST LLC SHORT-TERM
RENTAL CU/BTR APPLICATIONS
NOT SUBMITTED UNIT 1
OIG
EXHIBIT 8
1330 15TH ST LLC SMOKE
DETECTOR REPORT
OIG
EXHIBIT 9
1330 15TH ST LLC
RESORT TAX
REGISTRATION FORM
OIG
EXHIBIT 10
1330 15TH ST LLC
STATE OF FLORIDA
LICENSE
STATE OF FLORIDADEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION
TAP2330379 12/18/2019 TRANSIENT APARTMENT (2003) 1330 15TH STREET LLC1330 15TH STREET LLC
IS LICENSED under the provisions of Ch.509 FS.
Congratulations! With this license you become one of the nearly one million Floridians licensed by the Department of Business and Professional Regulation. Our professionals and businesses range from architects to yacht brokers, from boxers to barbeque restaurants, and they keep Florida’s economy strong. Every day we work to improve the way we do business in order to serve you better. For information about our services, please log onto www.myfloridalicense.com. There you can find more information about our divisions and the regulations that impact you, subscribe to department newsletters and learn more about the Department’s initiatives. Our mission at the Department is: License Efficiently, Regulate Fairly. We constantly strive to serve you better so that you can serve your customers. Thank you for doing business in Florida,and congratulations on your new license!Expiration date
STATE OF FLORIDA
DISPLAY AS REQUIRED BY LAWISSUED:SEQ #
ISSUED:
DETACH HERE
DIVISION OF HOTELS AND RESTAURANTS2601 BLAIR STONE ROADTALLAHASSEE FL 32399-1011
850-487-1395
ANANTHAN THANGAVEL1330 15TH STREET LLC1504 BAY RD APT 720MIAMI BEACH FL 33139
L1912180000086
DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATIONDIVISION OF HOTELS AND RESTAURANTS
The TRANSIENT APARTMENT (2003)Named below IS LICENSEDUnder the provisions of Chapter 509 FS.Expiration date: OCT 1, 2020
1330 15TH STREET LLC1330 15TH STREET LLC1330 15 STMIAMI BEACH FL 33139
RON DESANTIS, GOVERNOR HALSEY BESHEARS, SECRETARY
12/18/2019 L1912180000086
NBR. OF UNITS: 8
: OCT 1, 2020
. NON- .
. TRANSFERABLE .
STATE OF FLORIDA
DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION
LICENSE NUMBER
TAP2330379
Melanie S. Griffin, SecretaryRon DeSantis, GovernorSTATE OF FLORIDADEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATIONDIVISION OF HOTELS AND RESTAURANTSTHE TRANSIENT APARTMENT (2003) HEREIN IS LICENSED UNDER THEPROVISIONS OF CHAPTER 509, FLORIDA STATUTES1330 15TH STREET LLCDo not alter this document in any form.1330 15TH STREET LLCLICENSE NUMBER: TAP2330379EXPIRATION DATE: OCTOBER 1, 2023This is your license. It is unlawful for anyone other than the licensee to use this document.1330 15 STMIAMI BEACH FL 33139Always verify licenses online at MyFloridaLicense.comNBR. OF UNITS: 8