TRENTON, N.J. -- After a brazen, eight-month legislative spree, Gov. Jim Florio has left the residents of this state reeling.

From the people who feel betrayed by his $2.8 billion tax package, the largest state tax increase in the history of the United States, to those who are giddy with joy at his legislative and social initiatives, nobody quite knows what to make of the first-term Democrat. Still trying to figure out the shape of politics after Ronald Reagan, both his detractors and his proponents are asking themselves whether Florio is the last of the Old Liberals or the first in a line of New Liberals.

"He is an ideological liberal, the type that died 10 years ago," said Roger Stone, a Republican campaign consultant. "He believes in redistributing the wealth, taxing the rich and middle class and funneling it to the poor. It didn't work before and it won't work now. And when he fails, we will bury liberalism once and for all."

Stone's assessment is mild compared to what many of this state's residents are saying about the former boxer and eight-term member of Congress.

"He is not what I expected, and the Jim Florio who is governor of New Jersey is not the person I voted for," said Mary Elway, a computer store manager from Fort Lee, after watching him deliver a recent speech explaining his tax policies on statewide television. "I know you have to give a new person some time, but I really do feel cheated."

Elected in a landslide last November to the seat held securely for eight years by Republican Thomas H. Kean, a popular apostle of Reagan economic policies, Florio arrived in Trenton at the same time the economy was slumping and immediately began to dismantle the old regime.

He hammered out a massive reform of the state's regressive and costly auto insurance system within days of his inauguration. Then, taking on one of the nation's most powerful and determined state gun lobbies, he pushed through the most comprehensive ban on assault weapons in the country.

But Florio's most significant -- and bitterly contested -- action was to win legislative approval for a complete restructuring of the state's tax system, allowing him to go far beyond a state Supreme Court mandate to provide a more equal funding formula for rich and poor school districts. In June, Florio signed into law income and sales tax increases that will essentially shift billions of dollars from wealthy, and mainly suburban, state residents to finance the increase in funds for poor school districts and provide property tax rebates for home owners with incomes of less than $70,000 a year.

"It's pure betrayal and lies," said Walter Bubien, a commodity trader from East Brunswick who helped start Hands Across New Jersey, a grass-roots organization that has assembled several hundred thousand signatures to protest the Florio-backed tax increases. "He said during the campaign he didn't see a reason to raise sales taxes. He certainly didn't have to raise them this much."

At the moment, Florio finds himself besieged by the middle- and working-class residents he says will benefit the most from his policies. They are now paying higher sales taxes, and their property tax rebates are at least a year away. Meanwhile, the education reforms the higher taxes are to finance will take years to produce results. Recent opinion polls suggest that fewer than one in four New Jersey residents approves of Florio's actions in the first eight months on the job.

"Florio really honestly believes in what he is doing," said Carter Eskew, his Washington-based media adviser during the 1989 campaign. "He knows that problems don't go away overnight. But he also knows that they don't go away by talking. He does care about the political consequences of his actions, but he sees himself as doing his job."

Florio argues that he got stiffed by a huge and largely unexpected bill left over from the Kean administration. After the boom most northeastern states enjoyed during the 1980s, the economy slowed significantly here in the past two years. Projected budget surpluses quickly became red ink and Florio had to shear about $2 billion from Kean's last budget. Forced by state law to balance the budget, he then raised another $1.5 billion through a sales tax increase.

"We had to do it that way," said Florio, sipping coffee in a Princeton hotel before trying to sell his program to some of the state's leading business executives. "We weren't given many alternatives."

He defends his actions almost with the back of the hand.

"Everyone walks in here and says, 'My God, you are making decisions that are hard and people are reacting,' " he said. "Well, what have we been waiting for? We have been seduced into a stupor in the last decade. My great hero, Joe Louis, always said you can run but you can't hide. I think it's time to stop running."

Politicians here do not fault Florio so much for trying to take on New Jersey's major problems as they do for attempting to solve all those problems at once. To the critics, it is the $1.3 billion increase in income taxes, to be used expressly to reduce inequities in the state's school financing system, that has caused the most outrage. Some see it as outright socialism, and even those who are more sympathetic to Florio say that he might have been more effective had he stretched the tax increases over more than one year.

"He's like a car on ice," said the Republican state Assembly leader, Chuck Haytaian. "He is just out of control. He wants to look like a man on a mission in Washington. The trouble is we all live here."

Florio and the small band of advisers he trusts say they are unconcerned about the initial reaction to the income tax hike.

"Trying to handicap the future after seven months is a little hopeless," said state treasurer and former campaign manager Douglas Berman, who has clearly been Florio's closest adviser in devising the tax package. "But the governor is very comfortable with making these kinds of difficult decisions. He sees a need to help cities, to help poor children get a decent education. And it's not a sentimental vision. He understands that if we want to compete in the future, we have to have a work force that can read."

Few would disagree with that assertion, or deny that Newark and other New Jersey urban centers are far worse off than their suburban neighbors. But many here wonder whether moving funds from rich school systems to poor districts will solve the state's education problems. Florio's program of shifting the burden of financing education from local property taxes to a progressive state income tax could as much as double the state taxes on families with incomes of more than $150,000 and single people with incomes of more than $75,000.

"He has now gone to the rich people of New Jersey and taken their money and said, 'I made you pay for all this,' " said Paul Maslin, a Democratic political consultant who worked for Florio in 1989 before leaving the campaign for what he described as "mutual reasons." "So he better come up with something to show them.

"You have to give him credit for standing up and saying we can't wish this thing away," Maslin continued. "He sees his cities going down the drain and he wants it stopped. It's a good idea; the question is, will it ever really work?"