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Florida Statute 194.32 - Full Text and Legal Analysis
Florida Statute 194.032 | Lawyer Caselaw & Research
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The 2025 Florida Statutes

Title XIV
TAXATION AND FINANCE
Chapter 194
ADMINISTRATIVE AND JUDICIAL REVIEW OF PROPERTY TAXES
View Entire Chapter
F.S. 194.032
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.

F.S. 194.032 on Google Scholar

F.S. 194.032 on CourtListener

Amendments to 194.032


Annotations, Discussions, Cases:

Cases Citing Statute 194.032

Total Results: 36

Allen v. Butterworth

756 So. 2d 52, 2000 WL 381484

Supreme Court of Florida | Filed: Apr 14, 2000 | Docket: 471304

Cited 53 times | Published

Board from enforcing its decision, pursuant to section 194.032(6)(a), Florida Statutes (Supp.1976). The circuit

Bath Club, Inc. v. DADE CTY.

394 So. 2d 110, 1981 Fla. LEXIS 2521

Supreme Court of Florida | Filed: Jan 29, 1981 | Docket: 1315487

Cited 30 times | Published

DCA 1961). 3. Lastly, the Club asserts that section 194.032(4), Florida Statutes (Supp. 1976), which allows

Bystrom v. EQUITABLE LIFE ASSUR. SOC., ETC.

416 So. 2d 1133

District Court of Appeal of Florida | Filed: Mar 31, 1982 | Docket: 1224667

Cited 20 times | Published

filing suit in the circuit court pursuant to Section 194.032(6)(a), Paragraphs 1 and 2, Florida Statutes

CROSSINGS AT FLEMING ISLAND COMMUNITY DEV. DIST. v. Echeverri

991 So. 2d 793, 33 Fla. L. Weekly Supp. 445, 2008 Fla. LEXIS 1222, 2008 WL 2609005

Supreme Court of Florida | Filed: Jul 3, 2008 | Docket: 1724813

Cited 11 times | Published

significantly, that same year the Legislature amended section 194.032, Florida Statutes, to provide a method of appealing

Bystrom v. Valencia Center, Inc.

432 So. 2d 108

District Court of Appeal of Florida | Filed: Apr 26, 1983 | Docket: 1264612

Cited 10 times | Published

filed suit, pursuant to the requirement of Section 194.032(6)(a)(2), Florida Statutes (1979), which requires

Williams v. Law

368 So. 2d 1285

Supreme Court of Florida | Filed: Mar 8, 1979 | Docket: 1388880

Cited 10 times | Published

filed an action in circuit court pursuant to section 194.032(6)(a), Florida Statutes (Supp. 1976), seeking

Miller v. Nolte

453 So. 2d 397

Supreme Court of Florida | Filed: Jul 12, 1984 | Docket: 1651315

Cited 8 times | Published

perform a duty it owed to the taxpayer under section 194.032(5), Florida Statutes (1979). That section requires

Cape Cave Corp. v. Lowe

411 So. 2d 887

District Court of Appeal of Florida | Filed: Jan 29, 1982 | Docket: 1327336

Cited 6 times | Published

the PAAB hearing procedure is governed by Section 194.032, Florida Statutes (Supp. 1980). That section

GREENS OF INVERRARY CONDO. ASS'N v. Johnson

445 So. 2d 1096

District Court of Appeal of Florida | Filed: Feb 29, 1984 | Docket: 1685617

Cited 5 times | Published

before the Property Appraisal Adjustment Board (Section 194.032, Florida Statutes (1981)) or by means of judicial

Spooner v. Askew

345 So. 2d 1055

Supreme Court of Florida | Filed: Dec 22, 1976 | Docket: 1477949

Cited 5 times | Published

19, 1973. On October 30, 1973, pursuant to Section 194.032, Florida Statutes (1973), the Gadsden County

Fredericks v. Blake

382 So. 2d 368

District Court of Appeal of Florida | Filed: Mar 18, 1980 | Docket: 1674247

Cited 4 times | Published

complaint hearings to be held pursuant to Section 194.032, Florida Statutes (1977). He also asked that

Nikolits v. Ballinger

736 So. 2d 1253, 1999 WL 493103

District Court of Appeal of Florida | Filed: Jul 14, 1999 | Docket: 1736635

Cited 3 times | Published

see §§ 194.011-032, Fla. Stat. (1997). Under section 194.032(1)(b), "the value adjustment board may meet

Bystrom v. Union Land Inv., Inc.

477 So. 2d 585, 10 Fla. L. Weekly 2521

District Court of Appeal of Florida | Filed: Aug 6, 1985 | Docket: 1320754

Cited 3 times | Published

Property Appraiser filed an action pursuant to Section 194.032(6)(a) 1. and 2., Florida Statutes (1981), seeking

STATE, DEPT. OF REVENUE v. Markham

426 So. 2d 555

District Court of Appeal of Florida | Filed: Oct 22, 1982 | Docket: 1283463

Cited 3 times | Published

impediment rather than as an avenue of relief, and section 194.032(3), Florida Statutes (Supp. 1980), authorizes

Muss v. Blake

416 So. 2d 2

District Court of Appeal of Florida | Filed: May 25, 1982 | Docket: 2524393

Cited 3 times | Published

novo proceeding in the Circuit Court, see Section 194.032(6)(a)2, Florida Statutes (1977), satisfied

Bystrom v. Florida Rock Industries, Inc.

452 So. 2d 1053

District Court of Appeal of Florida | Filed: Jul 10, 1984 | Docket: 1517689

Cited 2 times | Published

the PAAB conduct all hearings required by Section 194.032, Florida Statutes (1981), and render its decision

Higgs v. PROP. APPRAISAL ADJ. BD., ETC.

411 So. 2d 307

District Court of Appeal of Florida | Filed: Mar 23, 1982 | Docket: 1327245

Cited 2 times | Published

injunctive and other relief sought pursuant to Section 194.032(6)(a)(3), Florida Statutes (1977), against

Wal-Mart Stores, Inc. v. Day

742 So. 2d 408, 1999 Fla. App. LEXIS 11868, 1999 WL 682609

District Court of Appeal of Florida | Filed: Sep 3, 1999 | Docket: 1303150

Cited 1 times | Published

applicable, and again after all hearings required by § 194.032 have been held. These certificates shall be attached

Wayne Johansson v. Miami-Dade County Value Adjustment Board

District Court of Appeal of Florida | Filed: Dec 13, 2023 | Docket: 68084521

Published

actions brought in the circuit court pursuant to section 194.032, now section 194.036, are original actions

WAYNE C. JOHANSSON v. MIAMI-DADE COUNTY VALUE ADJUSTMENT BOARD

District Court of Appeal of Florida | Filed: May 4, 2022 | Docket: 63285646

Published

actions brought in the circuit court pursuant to section 194.032, now section 194.036, are original actions

Edward A. Crapo, in his capacity as Alachua County Property Appraiser v. Academy for Five Element Acupuncture, Inc., a Florida Non-Profit Corporation

District Court of Appeal of Florida | Filed: Jul 8, 2019 | Docket: 15885445

Published

authority to hear disputes involving exemptions. § 194.032(1)(a)3., Fla. Stat. The VAB’s role in exemption

Ago

Florida Attorney General Reports | Filed: Nov 24, 2009 | Docket: 3257062

Published

(2007), adopted 2008. 8 Section 194.032(1)(a), Fla. Stat. 9 Section 194.032(1)(b), Fla. Stat. 10 See

Ago

Florida Attorney General Reports | Filed: Feb 12, 2003 | Docket: 3258494

Published

membership of the school board. Pursuant to section 194.032(1)(a), Florida Statutes, the value adjustment

Ago

Florida Attorney General Reports | Filed: Oct 18, 2001 | Docket: 3255785

Published

015, Fla. Stat. 10 Id. 11 Section 194.032(1)(a), Fla. Stat. 12 Section 194.032(1)(a)1.-4., Fla. Stat. 13

Ago

Florida Attorney General Reports | Filed: May 23, 1996 | Docket: 3258403

Published

6 Section 194.011(1), Fla. Stat. (1995). 7 Section 194.032(1), Fla. Stat. (1995). In addition to hearing

Bystrom v. Florida Rock Industries, Inc.

502 So. 2d 35, 12 Fla. L. Weekly 309, 1987 Fla. App. LEXIS 6370

District Court of Appeal of Florida | Filed: Jan 20, 1987 | Docket: 64624865

Published

appraisal adjustment board decision pursuant to section 194.032(6)(a) 1. or 2. by the property appraiser shall

Redford v. Department of Revenue

478 So. 2d 808, 10 Fla. L. Weekly 448, 1985 Fla. LEXIS 1455

Supreme Court of Florida | Filed: Aug 30, 1985 | Docket: 64615594

Published

the board for hearings in accordance with section 194.032. The board, acting on its own volition, held

Miller v. Nolte

427 So. 2d 248, 1983 Fla. App. LEXIS 19119

District Court of Appeal of Florida | Filed: Feb 16, 1983 | Docket: 64595265

Published

AFFIRMED. HERSEY and GLICKSTEIN, JJ., concur. . Section 194.032(5), Florida Statutes (1981), requires that

St. Joe Paper Co. v. Metropolitan Dade County

418 So. 2d 1013, 1982 Fla. App. LEXIS 20105

District Court of Appeal of Florida | Filed: May 25, 1982 | Docket: 64591893

Published

respect, but actually affirms it by providing in section 194.032(3), that “nothing herein shall preclude an

Blake v. Oceancoast Corp.

417 So. 2d 1002, 1982 Fla. App. LEXIS 20101

District Court of Appeal of Florida | Filed: May 25, 1982 | Docket: 64591602

Published

involved a Property Appraiser’s action under Section 194.032(6)(a) 3, in which the issue is not the correctness

Bystrom v. Equitable Life Assurance Society of United States

416 So. 2d 1133, 1982 Fla. App. LEXIS 20620

District Court of Appeal of Florida | Filed: Mar 31, 1982 | Docket: 64591251

Published

assessed value is within the parameters of Section 194.-032(6)(a)2, Florida Statutes (1977), so as to

Ago

Florida Attorney General Reports | Filed: May 18, 1981 | Docket: 3257879

Published

experience in the real estate appraisal field. Section 194.032(4), F.S. (1980 Supp.), brought into the statutes

Mikos v. Property Appraisal Adjustment Board of Sarasota County

365 So. 2d 757, 1978 Fla. App. LEXIS 16704

District Court of Appeal of Florida | Filed: Nov 15, 1978 | Docket: 64567732

Published

We reverse. Pursuant to the provisions of Section 194.032(6)(a)(3), Florida Statutes (1977) the appellant

Property Appraisal Adjustment Board v. Florida Department of Revenue

349 So. 2d 804, 1977 Fla. App. LEXIS 16380

District Court of Appeal of Florida | Filed: Sep 9, 1977 | Docket: 64560081

Published

Sarasota County Property Appraiser pursuant to Section 194.032(6)(a)3, Florida Statutes (Supp.1976), the Department

Bailey v. Plaza Hotel Corp.

335 So. 2d 16, 1976 Fla. App. LEXIS 13849

District Court of Appeal of Florida | Filed: Jul 19, 1976 | Docket: 64554467

Published

hearing petitions relating to assessments. (See F.S. 194.032) We do not here consider the merits of appellee’s

Ago

Florida Attorney General Reports | Filed: Feb 27, 1974 | Docket: 3256389

Published

assessment roll after all hearings required by section 194.032 have been held. . . . If the board of tax adjustment