Florida Statutes

Fla. Stat. § 194.032 (2025)

Hearing purposes; timetable.

✓ 2025 Florida Statutes — current through the 2025 Regular Session

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194.032 Hearing purposes; timetable.—

(1)(a) The value adjustment board shall meet not earlier than 30 days and not later than 60 days after the mailing of the notice provided in s. 194.011(1); however, no board hearing shall be held before approval of all or any part of the assessment rolls by the Department of Revenue. The board shall meet for the following purposes:

1. Hearing petitions relating to assessments filed pursuant to s. 194.011(3).

2. Hearing complaints relating to homestead exemptions as provided for under s. 196.151.

3. Hearing appeals from exemptions denied, or disputes arising from exemptions granted, upon the filing of exemption applications under s. 196.011.

4. Hearing appeals concerning ad valorem tax deferrals and classifications.

5. Hearing appeals from determinations that a change of ownership under s. 193.155(3), a change of ownership or control under s. 193.1554(5) or s. 193.1555(5), or a qualifying improvement under s. 193.1555(5) has occurred.

(b) Notwithstanding the provisions of paragraph (a), the value adjustment board may meet prior to the approval of the assessment rolls by the Department of Revenue, but not earlier than July 1, to hear appeals pertaining to the denial by the property appraiser of exemptions, tax refunds under s. 197.319, agricultural and high-water recharge classifications, classifications as historic property used for commercial or certain nonprofit purposes, and deferrals under subparagraphs (a)2., 3., and 4. In such event, however, the board may not certify any assessments under s. 193.122 until the Department of Revenue has approved the assessments in accordance with s. 193.1142 and all hearings have been held with respect to the particular parcel under appeal.

(c) In no event may a hearing be held pursuant to this subsection relative to valuation issues prior to completion of the hearings required under s. 200.065(2)(c).

(2)(a) The clerk of the governing body of the county shall prepare a schedule of appearances before the board based on petitions timely filed with him or her. The clerk shall notify each petitioner of the scheduled time of his or her appearance at least 25 calendar days before the day of the scheduled appearance. The notice must indicate whether the petition has been scheduled to be heard at a particular time or during a block of time. If the petition has been scheduled to be heard within a block of time, the beginning and ending of that block of time must be indicated on the notice; however, as provided in paragraph (c), a petitioner may not be required to wait for more than a reasonable time, not to exceed 2 hours, after the beginning of the block of time. The notice must also provide information for the petitioner to appear at the hearing using electronic or other communication equipment if the county has not opted out as provided in paragraph (b). The property appraiser must provide a copy of the property record card containing information relevant to the computation of the current assessment, with confidential information redacted, to the petitioner upon receipt of the petition from the clerk regardless of whether the petitioner initiates evidence exchange, unless the property record card is available online from the property appraiser, in which case the property appraiser must notify the petitioner that the property record card is available online. The petitioner and the property appraiser may each reschedule the hearing a single time for good cause. As used in this paragraph, the term “good cause” means circumstances beyond the control of the person seeking to reschedule the hearing which reasonably prevent the party from having adequate representation at the hearing. If the hearing is rescheduled by the petitioner or the property appraiser, the clerk shall notify the petitioner of the rescheduled time of his or her appearance at least 15 calendar days before the day of the rescheduled appearance, unless this notice is waived by both parties.

(b)1. The value adjustment board must allow the petitioner to appear at a hearing using electronic or other communication equipment if a petitioner submits a written request to appear in such manner at least 10 calendar days before the date of the hearing. The clerk must ensure that all parties are notified of such written request.

2. The board must ensure that the equipment is adequate and functional for allowing clear communication among the participants and for creating the hearing records required by law. The hearing must be open to the public either by providing the ability for interested members of the public to join the hearing electronically or to monitor the hearing at the location of the board. The board must establish a uniform method for swearing witnesses; receiving evidence submitted by a petitioner and presenting evidence, before, during, or after the hearing; and placing testimony on the record.

3. The petitioner must submit and transmit evidence to the board in a format that can be processed, viewed, printed, and archived.

4. Counties having a population of less than 75,000 may opt out of providing a hearing using electronic or other communication equipment under this paragraph. In any county in which the board has opted out under this subparagraph, the clerk shall promptly notify any petitioner requesting a hearing using electronic or other communication equipment of such opt out.

(c) A petitioner may not be required to wait for more than a reasonable time, not to exceed 2 hours, after the scheduled time for the hearing to commence. If the hearing is not commenced within that time, the petitioner may inform the chairperson of the meeting that he or she intends to leave. If the petitioner leaves, the clerk shall reschedule the hearing, and the rescheduling is not considered to be a request to reschedule as provided in paragraph (a).

(d) Failure on three occasions with respect to any single tax year to convene at the scheduled time of meetings of the board is grounds for removal from office by the Governor for neglect of duties.

(3) The board shall remain in session from day to day until all petitions, complaints, appeals, and disputes are heard. If all or any part of an assessment roll has been disapproved by the department pursuant to s. 193.1142, the board shall reconvene to hear petitions, complaints, or appeals and disputes filed upon the finally approved roll or part of a roll.

History.—s. 4, ch. 69-140; ss. 21, 35, ch. 69-106; s. 27, ch. 70-243; s. 12, ch. 73-172; s. 6, ch. 74-234; s. 7, ch. 76-133; s. 3, ch. 76-234; s. 1, ch. 77-174; s. 13, ch. 77-301; ss. 1, 9, 37, ch. 80-274; s. 5, ch. 81-308; ss. 14, 16, ch. 82-208; ss. 9, 11, 23, 26, 80, ch. 82-226; ss. 20, 21, 22, 23, 24, 25, ch. 83-204; s. 146, ch. 91-112; s. 979, ch. 95-147; s. 5, ch. 96-204; s. 4, ch. 97-117; s. 2, ch. 98-52; s. 3, ch. 2002-18; s. 2, ch. 2004-349; s. 11, ch. 2012-193; s. 8, ch. 2013-109; s. 10, ch. 2016-128; s. 14, ch. 2018-118; s. 35, ch. 2022-5; s. 4, ch. 2022-97; s. 2, ch. 2022-272; s. 21, ch. 2024-3; s. 10, ch. 2025-208.

Notes of Decisions

Cited in 35 cases (3 in the last 5 years), 1976–2026 · leading case: Crossings at Fleming Island Cmty. Dev. Dist. v. Echeverri, 991 So. 2d 793 (Fla. 2008).

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Crossings at Fleming Island Cmty. Dev. Dist. v. Echeverri, 991 So. 2d 793 (Fla. 2008). · cites it 8× “More significantly, that same year the Legislature amended section 194.032, Florida Statutes, to provide a method of appealing the board's decision to the circuit courtthe first legislation to grant property appraisers a statutory right to file a lawsuit challenging a tax…”

Williams v. Law, 368 So. 2d 1285 (Fla. 1979). · cites it 10× “Therefore, if the action filed by appellant pursuant to section 194.032(6) were an appellate proceeding, appellees would be correct in their assertion that a property appraiser must seek review of a decision of the board within thirty days after it becomes final.”

Bath Club, Inc. v. DADE CTY., 394 So. 2d 110 (Fla. 1981). · cites it 5× “Lastly, the Club asserts that section 194.032(4), Florida Statutes (Supp.”

Allen v. Butterworth, 756 So. 2d 52 (Fla. 2000). · cites it 4× “171(2), Florida Statutes (1975), which provided a sixty-day time limit for instituting civil actions in circuit court to challenge property tax assessments, violated the Court's exclusive authority to adopt rules of practice and procedure.”

Miller v. Nolte, 453 So. 2d 397 (Fla. 1984). · cites it 6× “We consider it eminently reasonable, therefore, for a taxpayer to assume, as appellant appears to have assumed, that the PAAB will comply with section 194.032 and that it (the taxpayer) has at least forty days from the date of issuance of the PAAB's decision to file a complaint…”

Bystrom v. Equitable Life Assurance Soc'y of United States, 416 So. 2d 1133 (Fla. 3d DCA 1982). · cites it 12× “The Burden of Proof In the present case, the Appraiser challenged the Board’s reduced valuation by the filing of a suit in circuit court authorized by Section 194.032, supra. The Taxpayers filed an answer which contained a counterclaim seeking a valuation lower than that which…”

Cape Cave Corp. v. Lowe, 411 So. 2d 887 (Fla. 2d DCA 1982). · cites it 8× “If the taxpayer elects to pursue his administrative remedies, as appellant did here, the PAAB hearing procedure is governed by Section 194.032, Florida Statutes (Supp. 1980).”

Higgs v. Prop. Appraisal Adj. Bd., Etc., 411 So. 2d 307 (Fla. 3d DCA 1982). · cites it 11× “…inaudible, notwithstanding a separate statutory mandate that the Board make a verbatim record of the proceedings. See § 194.032(3), Fla. Stat. (1977).”

Bystrom v. Union Land Inv., Inc., 477 So. 2d 585 (Fla. 3d DCA 1985). · cites it 5× “The Property Appraiser filed an action pursuant to Section 194.032(6)(a) 1. and 2., Florida Statutes (1981), seeking to reinstate his original non-agricultural assessment of the property.”

Fredericks v. Blake, 382 So. 2d 368 (Fla. 3d DCA 1980). · cites it 4× “He requested that the court enjoin approval of the 1978 Dade County preliminary tax rolls by the Department of Revenue and all tax complaint hearings to be held pursuant to Section 194.032, Florida Statutes (1977).”

Bystrom v. Valencia Ctr., Inc., 432 So. 2d 108 (Fla. 3d DCA 1983). · cites it 2× “The Property Appraiser filed suit, pursuant to the requirement of Section 194.032(6)(a)(2), Florida Statutes (1979), which requires that suit be filed by the taxing official if the PAAB reduces the assessment by more than ten percent.”

Redford v. Dep't of Revenue, 478 So. 2d 808 (Fla. 1985). · cites it 3× “098, the appraiser adopted the department’s position and forwarded the corrected assessment rolls to the board for hearings in accordance with section 194.032. The board, acting on its own volition, held hearings on the leaseholds, determined that they were exempt, and certified…”

Show all 35 citing cases →

— 194.032(1)(a) — 1 case

Edward A. Crapo, in his capacity as Alachua Cnty. Prop. Appraiser v. Academy for Five Element Acupuncture, Inc., a Florida Non-Profit Corp. (Fla. 1st DCA 2019).

— 194.032(1)(b) — 1 case

Nikolits v. Ballinger, 736 So. 2d 1253 (Fla. 4th DCA 1999).

— 194.032(11) — 1 case

Certain Balmoral Condo. Unit Owners v. Bystrom, 17 Fla. Supp. 2d 88 (Fla. Cir. Ct. 1986).

— 194.032(2) — 2 cases

Miller v. Nolte, 453 So. 2d 397 (Fla. 1984). “We consider it eminently reasonable, therefore, for a taxpayer to assume, as appellant appears to have assumed, that the PAAB will comply with section 194.032 and that it (the taxpayer) has at least forty days from the date of issuance of the PAAB's decision to file a complaint…”

Tax Adjustment Experts of Florida, Inc. v. Brinker, 12 Fla. Supp. 2d 34 (Fla. Cir. Ct. 1984).

— 194.032(3) — 7 cases

State, Dept. of Revenue v. Markham, 426 So. 2d 555 (Fla. 4th DCA 1982).

Higgs v. Prop. Appraisal Adj. Bd., Etc., 411 So. 2d 307 (Fla. 3d DCA 1982). “…inaudible, notwithstanding a separate statutory mandate that the Board make a verbatim record of the proceedings. See § 194.032(3), Fla. Stat. (1977).”

Cape Cave Corp. v. Lowe, 411 So. 2d 887 (Fla. 2d DCA 1982). “If the taxpayer elects to pursue his administrative remedies, as appellant did here, the PAAB hearing procedure is governed by Section 194.032, Florida Statutes (Supp. 1980).”

Bystrom v. Equitable Life Assurance Soc'y of United States, 416 So. 2d 1133 (Fla. 3d DCA 1982). “The Burden of Proof In the present case, the Appraiser challenged the Board’s reduced valuation by the filing of a suit in circuit court authorized by Section 194.032, supra. The Taxpayers filed an answer which contained a counterclaim seeking a valuation lower than that which…”

Mikos v. Prop. Appraisal Adjustment Bd. of Sarasota Cnty., 365 So. 2d 757 (Fla. 2d DCA 1978).

— 194.032(4) — 1 case

Bath Club, Inc. v. DADE CTY., 394 So. 2d 110 (Fla. 1981). “Lastly, the Club asserts that section 194.032(4), Florida Statutes (Supp.”

— 194.032(5) — 4 cases

Miller v. Nolte, 427 So. 2d 248 (Fla. 4th DCA 1983).

— 194.032(6) — 7 cases

Williams v. Law, 368 So. 2d 1285 (Fla. 1979). “Therefore, if the action filed by appellant pursuant to section 194.032(6) were an appellate proceeding, appellees would be correct in their assertion that a property appraiser must seek review of a decision of the board within thirty days after it becomes final.”

Allen v. Butterworth, 756 So. 2d 52 (Fla. 2000). “171(2), Florida Statutes (1975), which provided a sixty-day time limit for instituting civil actions in circuit court to challenge property tax assessments, violated the Court's exclusive authority to adopt rules of practice and procedure.”

Crossings at Fleming Island Cmty. Dev. Dist. v. Echeverri, 991 So. 2d 793 (Fla. 2008). “More significantly, that same year the Legislature amended section 194.032, Florida Statutes, to provide a method of appealing the board's decision to the circuit courtthe first legislation to grant property appraisers a statutory right to file a lawsuit challenging a tax…”

Mikos v. Prop. Appraisal Adjustment Bd. of Sarasota Cnty., 365 So. 2d 757 (Fla. 2d DCA 1978).

— 194.032(6)(a) — 10 cases

Bystrom v. Equitable Life Assur. Soc., Etc., 416 So. 2d 1133 (Fla. 3d DCA 1982).

— 194.032(6)(a)(2) — 1 case

Bystrom v. Valencia Ctr., Inc., 432 So. 2d 108 (Fla. 3d DCA 1983). “The Property Appraiser filed suit, pursuant to the requirement of Section 194.032(6)(a)(2), Florida Statutes (1979), which requires that suit be filed by the taxing official if the PAAB reduces the assessment by more than ten percent.”

— 194.032(6)(a)(3) — 3 cases

Mikos v. Prop. Appraisal Adjustment Bd. of Sarasota Cnty., 365 So. 2d 757 (Fla. 2d DCA 1978).

Wayne C. Johansson v. Miami-dade Cnty. Value Adjustment Bd. (Fla. 3d DCA 2022).

— 194.032(6)(a)(3)(c) — 1 case

— 194.032(6)(a)(l) — 1 case

Bystrom v. Moses, 23 Fla. Supp. 2d 49 (Fla. Cir. Ct. 1987).

— 194.032(6)(b) — 2 cases

Bystrom v. Equitable Life Assur. Soc., Etc., 416 So. 2d 1133 (Fla. 3d DCA 1982).

— 194.032(6)(c) — 4 cases

Bath Club, Inc. v. DADE CTY., 394 So. 2d 110 (Fla. 1981). “Lastly, the Club asserts that section 194.032(4), Florida Statutes (Supp.”

Bystrom v. Union Land Inv., Inc., 477 So. 2d 585 (Fla. 3d DCA 1985). “The Property Appraiser filed an action pursuant to Section 194.032(6)(a) 1. and 2., Florida Statutes (1981), seeking to reinstate his original non-agricultural assessment of the property.”

Bystrom v. Equitable Life Assur. Soc., Etc., 416 So. 2d 1133 (Fla. 3d DCA 1982).

— 194.032(l)(c) — 1 case

Redford v. Dep't of Revenue, 478 So. 2d 808 (Fla. 1985). “098, the appraiser adopted the department’s position and forwarded the corrected assessment rolls to the board for hearings in accordance with section 194.032. The board, acting on its own volition, held hearings on the leaseholds, determined that they were exempt, and certified…”

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