Miami says it should not have to pay property taxes on the four parking garages it built at the new Little Havana ballpark for the Miami Marlins. The Miami-Dade County property appraiser suggests otherwise. And now both sides are poring over state law to make their case.

It’s not your run-of-the-mill bureaucratic tiff: The debate has also piqued the interest of the feds. The U.S. Securities and Exchange Commission has subpoenaed the county and city demanding details on the ballpark — including records relating to the tax question and how the $100 million bond deal to build the garages was put together.

The local tax issue boils down to this: Do the garages serve a public purpose? And if so, should they be tax-exempt like the stadium, which sits on county-owned land?

City officials believe they have nearly four decades of court rulings on their side saying that stadiums serve the public good. And if the garages are integral to the stadium — the stadium would likely not have been built without parking — then the garages should also be considered a benefit to the public, they say.

The Florida Constitution says that for a government-owned property to be exempt from taxes, it must be used solely for a public purpose. Pedro Garcia, the Miami-Dade property appraiser, has said letting the Marlins pay the city $10.03 a space to use the garage’s 5,700 spaces for the team’s 81 home games each year constitutes having a private enterprise operating on public property. As such, it could be subject to taxes that could amount to about $1.2 million a year.

Miami counters that the garages should be exempt because they serve the public by being open 24 hours a day, seven days a week.

City Attorney Julie Bru also insists that the city hasn’t actually leased the garages to the Marlins. Leasing involves turning over exclusive use, control and possession of a property, she said. Though Marlins fans will pay the team to park in the garages during games, the garages will still be operated by the Miami Parking Authority, even on game days.

Bru calls the city’s parking agreement with the Marlins a “bulk sale” — the city sold the spaces to the ballclub for certain hours a day, certain days a year, for a fee.

It’s unclear, however, how many people not going to a ballgame would be able to park in the garages during game days — not that much demand is anticipated.

Parking Authority CEO Art Noriega says drivers who do not have parking passes sold to Marlins season-ticket holders will still be able to park in the garages — eventually. At first, only drivers with Marlins parking passes will be allowed in, until the ballclub and city figure out how many parking spaces will be available for the public.

“It’s really going to be dependent on how much parking they’re going to pre-sell,” Noriega said of the Marlins.

Beyond the Florida Constitution, state statutes say that government property leased to an organization is tax-exempt if the property is used for a public purpose or exclusively for literary, scientific, religious or charitable purposes.

But Bru cites another provision in state law that says government property must have “predominant or exclusive” public use to be tax-exempt. For Bru, the “predominant” distinction is key: according to the provision, it means a property is used for public purposes more than 50 percent of the time.