The 2023 Florida Statutes (including Special Session C)
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. . . . § 194.171, Fla. Stat. . . . . §§ 194.036(2), 194.171, Fla. Stat. . . .
. . . subject matter jurisdiction to consider the challenge to the 2015 and 2016 years pursuant to section 194.171 . . . Section 194.171 provides in relevant part: (5) No action to contest a tax assessment may be maintained . . . As the Florida Supreme Court has observed: Although subsections 194.171(5) and (6) appear to be somewhat . . . Subsection 194.171(5) plainly states that a taxpayer may not maintain a suit contesting a tax assessment . . . Section 194.171(2), Florida Statutes, requires a taxpayer to contest a tax assessment within "60 days . . .
. . . failed to file suit within 60 days after the certification of the tax rolls as required under section 194.171 . . . We held that the 60-day period in section 194.171(2) does not apply to actions challenging a tax lien . . .
. . . See, e.g. , § 194.171(2), Fla. Stat. (2017). . . .
. . . trustee, has standing to contest the tax assessment and is not barred by the time limit of section 194.171 . . .
. . . Dadeland Station paid the taxes under protest and filed a suit to recover the payment under section 194.171 . . .
. . . The City argues that the sixty-day non-claim provision of section 194.171(2) bars the action below and . . . Section 194.171(2) provides: No action shall be brought to contest a tax assessment after 60 days from . . . Section 194.171(6) provides that the “requirements of subseetion[ ] (2) ... are jurisdictional” and that . . . While we are doubtful that section 194.171(2) applies to the instant case, we need not decide that issue . . . Even if section 194.171(2) does apply, the City’s position is nevertheless unavailing, because the City . . .
. . . jurisdiction, ruling that it had been filed beyond the sixty-day statute of non-claim under section 194.171 . . . Appraiser sent the notice on February 20 — well beyond the sixty-day statute of nonclaim under section 194.171 . . . period: the certification of the assessment pursuant to section 193.122(2). § 194.171(2). . . . There, the court stated: Section 194.171(2), by its clear and unambiguous terms, applies only to actions . . . Accordingly, if section 194.171(2)-was construed to apply to tax liens, the only opportunity a property . . .
. . . the court had jurisdiction when the action was filed, it subsequently lost jurisdiction under section 194.171 . . . Brooke argues, among other things, that the trial court departed from the plain meaning of section 194.171 . . . See § 194.171(8). . . . There is no mistaking the clear language of section 194.171(5): a taxpayer may not maintain an action . . . See Marshall, 494 So.2d at 507 (recognizing that the legislative objective of section 194.171 is “the . . .
. . . Neptune Hollywood Beach Club, 527 So.2d 814, 816 (Fla.1988) (holding that analogous language in section 194.171 . . .
. . . Genesis argues that the trial court erred in finding that its challenge was barred by section 194.171 . . . Neptune Hollywood Beach Club, 527 So.2d 814, 816 (Fla.1988); see also § 194.171(6), Fla. Stat. . . . However, we have previously held that the 60— day period in section 194.171(2) does not begin to run . . . Section 194.171 does not refer to section 196.0ll(9)(a) nor does it mention tax liens. . . . The Court rejected this “semantic argument” and -held that taxpayers are bound by section 194.171(2) . . .
. . . On the City of Miami’s acknowledgement that the application of section 194.171 of the Florida Statutes . . . address the trial court’s factual or legal determinations as to the applicability of either section 194.171 . . .
. . . Section 194.171(2), Florida Statutes (2012), is a jurisdictional statute of non-claim that precludes . . . any challenge to the 2012 just value assessment of the former homestead was time barred by section 194.171 . . . moved for summary judgment arguing, among other things, that Neffs action was time barred by section 194.171 . . . Section 194.171(2) is a jurisdictional statute of non-claim. See § 194.171(6), Fla. . . . The strict jurisdictional time limit of section 194.171(2) cannot be circumvented by embedding a challenge . . .
. . . inter alia, that its claims were barred by: (1) the sixty-day non-claim statute pursuant to section 194.171 . . .
. . . Appellees filed a motion to dismiss the complaint for lack of jurisdiction under section 194.171(2), . . . Department of Management Services, 944 So.2d 306 (Fla.2006) (the 60-day jurisdictional time limit in section 194.171 . . . trustee, has standing to contest the tax assessment and is not barred by the time limit of section 194.171 . . .
. . . . § 194.171(2) (2009). . . . Section 194.171(2), Fla. . . . Section 194.171(6), Fla. . . .
. . . . § 194.171(2) (2009). . . . Section 194.171(2), Fla. . . . Section 194.171(6), Fla. . . .
. . . and II of the third amended complaint for lack of subject matter jurisdiction pursuant to subsections 194.171 . . . They argue that because they do not pose a challenge to a tax assessment, the provisions of section 194.171 . . . It does not matter whether the challenge is brought under section 196.151 or 194.171. See Ward v. . . . rejecting taxpayers’ semantic argument that they were not subject to sixty-day time limit of section 194.171 . . . Pursuant to the clear language of subsections 194.171(5) & (6), the petition is granted. . . .
. . . 2011, deadline and, consequently, the trial court lost jurisdiction over the case pursuant to section 194.171 . . . Section 194.171(5) provides in full: “No action to contest a tax assessment may be maintained, and any . . . Therefore, once taxes become delinquent, dismissal is required pursuant to section 194.171. . . . Once the Trustee’s taxes became delinquent on April 1, 2011, section 194.171 divested the trial court . . .
. . . Indeed, tax liens could not have been placed on any of the property since section 194.171, Florida Statutes . . .
. . . This is so because a taxpayer is barred by sections 194.171(2) and (6), Florida Statutes (2010), from . . .
. . . Also, South Pointe claimed it was exempt from the jurisdictional requirements of section 194.171, Florida . . . Section 194.171(2), Florida Statutes (2007), states (2) No action shall be brought to contest a tax assessment . . . received final action by the value adjustment board prior to extension of the roll under s. 197.323. § 194.171 . . . (5) and 194.171(6), Florida Statutes. . . . (5), 194.171(6), Fla. . . .
. . . Bennett filed his lawsuit pursuant to section 194.171, Florida Statutes (2008), challenging the denial . . . Section 194.171 governs suits against the property appraiser contesting tax assessments and provides . . . collection or within sixty days from the date a decision is rendered by the VAB as to such assessment. § 194.171 . . . The court expressly granted the property appraiser’s motion based upon section 194.171 but denied it . . . jurisdiction in such cases until after the requirements of both subsections (2) and (8) [of section 194.171 . . .
. . . See § 194.171(1), Fla. Stat. (2008); Deluccio v. Havill, 25 So.3d 31 (Fla. 1st DCA 2009). . . .
. . . . § 194.171(2) (2009). . . . . Stat. § 194.171(2). . Fla. Stat. § 194.171(1). . . .
. . . See § 194.171(1), Fla. Stat. (2006). . . .
. . . In doing so, we confirm the applicability of the non-claim statute, § 194.171, to that challenge. . . . imposition of the special DDA levy also required compli-anee with the non-claim statute, section § 194.171 . . .
. . . Further, subsection (2) of section 194.171 sets forth a sixty-day limit for challenging tax assessments . . .
. . . 944 So.2d 306, 308 (Fla.2006), the supreme court interpreted the term “taxpayer” as used in section 194.171 . . . Because section 194.171 did not define “taxpayer,” the supreme court looked at the definition of “taxpayer . . .
. . . erroneously concluded that it lacked subject matter jurisdiction when appellants did not comply with section 194.171 . . .
. . . had subject matter jurisdiction despite appellants/cross-appellees’ failure to comply with section 194.171 . . .
. . . See § 194.171(2), Fla. Stat. (2003). . . . The County argues, and the trial court agreed, that the Association’s action is barred by subsection 194.171 . . . The claim is not barred by subsection 194.171(2). . . . assessment of the property which was time-barred under the sixty-day limit established by subsection 194.171 . . .
. . . contend that the trial-court should have dismissed the case for lack of jurisdiction, because section 194.171 . . . There we held that the sixty-day time period in section 194.171 applies only to an action to contest . . . Section 194.171, Florida Statutes states in material part: 194.171 Circuit court to have original jurisdiction . . . the assessment made on any particular property in Florida, and so the sixty-day provision in section 194.171 . . . the trial court had properly dismissed the case for failure to file within sixty days under section 194.171 . . .
. . . court found that the Shanks had failed to comply with the conditions precedent set forth in section 194.171 . . . Section 194.171(6) provides that the requirements of subsections (2), (3), and (5) are jurisdictional . . . We respectfully disagree with the trial court’s interpretation of section 194.171. . . . Section 194.171(6) provides that no court shall have jurisdiction in a case challenging a property tax . . . day of the sixty-day time period, and otherwise complied with the requirements set forth in section 194.171 . . .
. . . before the board of tax adjustment would not preclude an action in the circuit court pursuant to section 194.171 . . . subsection 194.032(6) provided that a taxpayer could file an action in the circuit court pursuant to section 194.171 . . . 194.036(2) provides that a taxpayer could bring an action to contest a tax assessment pursuant to section 194.171 . . . aggrieved taxpayer from contesting [in circuit court] his or her assessment in the manner provided by s. 194.171 . . .
. . . See § 194.171(3), Fla. Stat. (2002-2005). . . .
. . . See § 194.171(2), (6), Fla. Stat. (2005). . . .
. . . See § 194.171(1), Fla. . . .
. . . complaint was not attached to the motion to amend and that the sixty-day filing period specified in section 194.171 . . . Second, subsection (2) of 194.171, Florida Statutes, provides that “[n]o action shall be brought to contest . . .
. . . Alvarez moved to dismiss the complaint as untimely under the provisions of section 194.171(2), Florida . . .
. . . See §§ 194.171(5), (6), Fla. Stat. (2003); Bystrom v. Diaz, 514 So.2d 1072, 1075 (Fla.1987). . . .
. . . on the application of section 194.171 to actions filed by the State. . . . Section 194.171(2) provides that “[n]o action shall be brought” beyond the sixty-day period. . . . “Taxpayer” is not defined in section 194.171 or elsewhere in chapter 194. . . . In short, a “taxpayer” under section 194.171 is a taxable entity. . . . Rather, we simply determine that sections 194.171(2) and 194.171(6) do not deprive the trial court of . . .
. . . to dismiss and for summary judgment, on the ground that the sixty-day statute of non-claim, section 194.171 . . . Hidden Bay contends that its claims are not governed by section 194.171 because the Property Appraiser . . . In Ward, the Florida Supreme Court held that “the mandatory sixty-day provision of section 194.171(1) . . . The Ward court, guided by legislative intent and public policy, held that section 194.171 was adopted . . . Section 194.171, Florida Statutes, states, in relevant part: (2) No action shall be brought to contest . . .
. . . the property within 60 days from the date of its certification for collection, as required by section 194.171 . . . failure to challenge the assessments on the property within the limitation period required by section 194.171 . . . issue before us in that the lower court’s decision turned primarily upon an interpretation of section 194.171 . . . Nor do we find any provision in section 194.171, or elsewhere, reasonably implying that the nonclaim . . . This section, as section 194.171, is placed under Part II of chapter 194, Florida Statutes, pertaining . . .
. . . proof of claim and highlights the dilemma of the estate, where the response states that under section 194.171 . . .
. . . Section 194.171 of the Florida Statutes confers jurisdiction on the circuit courts to hear ad valorem . . . Section 194.171 also makes clear that jurisdiction to entertain an assessment contest is conditioned . . . Friedman, 625 So.2d 83, 84 (Fla. 3d DCA 1993) (“[i]t is now settled beyond any doubt that [section 194.171 . . . Although section 194.171 suspends these deadlines while an assessment is being contested, it does so . . . Wright, 687 So.2d 1374, 1374-75 (Fla. 1st DCA 1997) (emphasis added); § 194.171(5), (6), Fla. . . .
. . . with the statutory conditions precedent for challenging an excessive assessment pursuant to Section 194.171 . . .
. . . dismiss the complaint on the ground that the taxpayer failed to comply with the requirements of section 194.171 . . . The taxpayers contended that section 194.171 did not apply to them because they were challenging the . . . Like the taxpayers in Ward, Pultz did not comply with the requirements of section 194.171. . . . In this case, the taxpayer did not comply with section 194.171(3), which requires the taxpayer to pay . . . Section 194.171(6) expressly states that “[t]he requirements of subsections (2), (3) ... are jurisdictional . . .
. . . jurisdiction because the action had not been filed within the sixty-day window provided by section 194.171 . . . The supreme court recently disapproved our Pepperidge Farm decision and held that section 194.171(2) . . .
. . . We hold that the mandatory sixty-day provision of section 194.171(1), Florida Statutes, applies broadly . . . Leesburg Regional Medical Center, 651 So.2d 231 (Fla. 5th DCA 1995) (rejecting argument that 194.171 . . . In a petition for review in this Court the petitioners contend that section 194.171(2) does not apply . . . to their action. § 194.171(2), Fla. . . . Stat. (2001) This Court has held that the sixty-day filing period in section 194.171 is jurisdictional . . .
. . . Statutes (2001), assure sufficient notice to property appraisers, and the sixty-day deadline in section 194.171 . . .
. . . 2000, and 2001, the refunds sought by the Taxpayers were barred by the nonclaim statute in section 194.171 . . . the Taxpayers’ claims for relief for those years are barred by the statute of non-claim in section 194.171 . . .
. . . matter jurisdiction because the taxpayer did not pay the 2000 and 2001 taxes as required by section 194.171 . . .
. . . because the complaint had not been filed within the 60 day statute of nonclaim set forth in section 194.171 . . . appraiser’s tax classification of the property at issue, rather than to a tax assessment, and that section 194.171 . . .
. . . Patricia Lee appeal a final summary judgment in which the trial court ruled that, pursuant to section 194.171 . . . See § 194.171(2), Fla. Stat. (1999). As the court explained in Department of Revenue v. . . . , capricious, arbitrary and illegal,” the action is cognizable only under the strictures of section 194.171 . . . made in violation of section 193.155 is an action to contest an assessment and is governed by section 194.171 . . .
. . . Pep-peridge Farm’s complaint was a challenge to the assessment of property which, under subsection 194.171 . . . See § 194.171(6). . . . determination that Pepperidge Farm’s lawsuit was not one barred by the sixty-day time limit in section 194.171 . . .
. . . alleged that VGA had failed to file its complaint within the sixty-day period prescribed by section 194.171 . . .
. . . other things, that the challenge to the 2001 assessment was not timely filed in accordance with section 194.171 . . . This same rule of law should apply in the instant matter, which involves section 194.171(2), a statute . . . involves reclassification of property, and therefore they are not bound by the time limit of section 194.171 . . .
. . . certain members of the proposed class were time barred from bringing an action pursuant to section 194.171 . . . Appellants argue they were not subject to the 60 day time limits contained in section 194.171, Florida . . . Denial of exemptions are “assessments” subject to the requirements of section 194.171, Florida Statutes . . . Leesburg Regional Medical Center, 651 So.2d 231 (Fla. 5th DCA 1995) (rejecting argument that 194.171 . . . There, respondents failed to file action in court within sixty days, as mandated by section 194.171(2 . . .
. . . Friedman, 625 So.2d 83 (Fla. 3d DCA 1993); § 194.171(6), Fla. Stat. (2002). . . . defendant taxpayers moved to dismiss, contending that the claims were time barred pursuant to section 194.171 . . . Petitioners argue that section 194.171(2) should be given its plain meaning because it provides that . . . They also note that section 194.171(2) is the more recent expression of the Florida Legislature, having . . . Read in pari materia, 194.171(2) has no bearing on appeals by the property appraiser to the circuit court . . .
. . . assessment of its property for the years 1999 and 2000, Venice Golf filed suit pursuant to section 194.171 . . .
. . . exemption for the tax years 1997 and 1998, and Concorde filed suit in circuit court pursuant to section 194.171 . . .
. . . final judicial decision to file an action to contest such altered or changed assessment pursuant to s. 194.171 . . . (1), and the provisions of s. 194.171(2) shall not bar such action. (2) Any taxpayer may bring an action . . . to contest a tax assessment pursuant to s. 194.171. (3) The circuit court proceeding shall be de novo . . .
. . . See § 194.171(2), Florida Statutes (1999); Markham v. . . . Neptune Hollywood Beach Club, 527 So.2d 814 (Fla.1988) (holding that section 194.171(2) is a jurisdictional . . . As it is clear the court lacked jurisdiction under subsection 194.171(2), we need not address whether . . . the court was correct in ruling thal subsection 194.171(5) also operated to deprive the courL of jurisdiction . . .
. . . See § 194.171, Fla. Stat. (1997); Nikolits v. . . . Delaney, 719 So.2d 348 (Fla. 4th DCA 1998)(subsection 194.171(2)’s time limit provides for subject matter . . .
. . . Heffner and Day filed motions for summary judgment, alleging the complaint was untimely based on section 194.171 . . . jurisdictional, and no court has jurisdiction in tax cases until subsections (1) and (2) are met. § 194.171 . . . A classification claim is not governed under section 194.171; a claim challenging a tax assessment is . . . ad valorem tax assessment as excessive, untimely where not filed within sixty-day period of section 194.171 . . . It is therefore not subject to the sixty-day period of section 194.171(2). Sartori; Sohn. . . .
. . . Adjustment Board to contest the assessment of ad valorem taxes within sixty days, as mandated by section 194.171 . . . Further, respondents are also barred by section 194.171 by their failure to contest the yearly assessments . . . Section 194.171, Florida Statutes, provides: (1) The circuit courts have original jurisdiction at law . . .
. . . defendants argued 1). that the Reinishes could not circumvent the jurisdictional requirements of section 194.171 . . . days from the date the assessment was certified for collection in any of the tax years in question. § 194.171 . . . On that basis, the defendants moved to dismiss for lack of subject-matter jurisdiction. § 194.171(6), . . .
. . . The circuit court also concluded that section 194.171(2), Florida Statutes (1975), which provided a sixty-day . . . The Court stated that the sixty-day limit set forth in section 194.171(2) “constitutes a statute of limitations . . .
. . . Case No. 92-10367 was thereafter commenced in accordance with Section 194.171, Florida Statutes. E. . . .
. . . Appellees answered asserting the affirmative defense of lack of subject matter jurisdiction under section 194.171 . . . Appellees thereafter filed a motion for summary judgment asserting that under section 194.171, Florida . . . that it had petitioned the value adjustment board contesting the assessment in compliance with section 194.171 . . . Section 194.171, Florida Statutes (1997), provides in pertinent part: (1) The circuit courts have original . . . See § 194.171(2) Fla. . . .
. . . rolls and was not filed within sixty days of the certification of the tax rolls as required by section 194.171 . . . The revenue collector filed an answer also raising the jurisdictional bar of section 194.171. . . . judgment as one challenging the property assessment and therefore argue it is untimely pursuant to section 194.171 . . . Thus, correction of these types of errors is not limited by section 194.171. . . . alleging an error in classification in property which would change its value was not governed by section 194.171 . . .
. . . 1997 tax assessment of property in two stores located in Osceola County was untimely under section 194.171 . . . Section 194.171 provides a 60-day time period in which to file ad valorem eases. . . . Section 194.171 is a jurisdictional non-claim statute. . . . Thus, Walker recognized the interrelationship of sections 197.323, 193.122, and 194.171(2). . . . That case involved the 1981 version of section 193.122 and section 194.171. . . .
. . . Section 194.171(2), Florida Statutes (1997) provides that “[n]o action shall be brought to contest a . . . Section 194.171(6) states that the requirements of subsection (2) are “jurisdictional.” . . . 646 So.2d 803, 805 (Fla. 4th DCA 1994), this court observed that the 60 day requirement of subsection 194.171 . . . 1997 tax assessment, or whether it was part of the 1996 “tax assessment” within the meaning of section 194.171 . . . to contest the denial, so long as the taxpayer fulfills the jurisdictional requirements of section 194.171 . . .
. . . Furthermore, DOR asserts that by failing to comply with § 194.171, Florida Statutes, which requires timely . . .
. . . unlawful taxation claims, because the Moore appellants failed to timely contest taxes pursuant to section 194.171 . . .
. . . section 193.155, Florida Statutes (1997), is an action to contest a tax assessment governed by section 194.171 . . . Since respondents’ action was filed beyond the sixty-day time limit prescribed by subsection 194.171( . . .
. . . moved to dismiss Sartori’s complaint arguing it was not timely filed because, pursuant to subsection 194.171 . . . Section 194.171 provides, in relevant part: 194.171 Circuit court to have original jurisdiction in tax . . . court concluded that Sartori’s lawsuit was untimely filed because this matter was governed by section 194.171 . . . Sartori argues that his declaratory judgment action was not subject to section 194.171’s sixty-day deadline . . . because, inter alia, the complaint was not filed within the sixty-day time period provided in section 194.171 . . .
. . . However, the time limit to contest a tax assessment, set forth in Section 194.171(2), Fla.Stat., is not . . .
. . . . § 194.171(2), (6), Fla. Stat. (1995). . . .
. . . The Department analogizes to section 194.171, Florida Statutes. In Markham v. . . . could not exercise jurisdiction over an ad valorem tax case because the 60-day time period in section 194.171 . . . The Department’s attempted analogy to section 194.171 fails because that statute expressly includes refund . . .
. . . Florida Statutes § 194.171 provides for a judicial review of the determination by the Board as to the . . . Stat. § 194.171(1). . . .
. . . Section 194.171, Florida Statutes (1995), provides: (3) Before an action to contest a tax assessment . . . In this regard, section 194.171, Florida Statutes (1995), provides: (5) No action to contest a tax assessment . . . assessment after 60 days from the date the assessment being contested is certified for collection.” § 194.171 . . . could no longer be deemed payment of amounts “which the taxpayer in good faith admits to be owing.” § 194.171 . . . dismissal of Washington Square’s complaint challenging its assessment for the taxable year 1993. § 194.171 . . .
. . . . § 194.171(2), Fla. Stat. (1995). . . .
. . . The circuit court held that pursuant to Florida Statute section 194.171(2) (1993), it did not have jurisdiction . . . Florida Statute section 194.171 (1988) provided that: (2) No action shall be brought to contest a tax . . .
. . . had not been filed within 60 days of the rendering of the Board’s decision, as required by section 194.171 . . . strictly comply with the statutory notice procedures may toll the running of the 60-day period in section 194.171 . . . Rule 1.090(e) clearly does not apply to the computation of the time periods under section 194.171(2), . . .
. . . In Chihocky, the pertinent statutory provision, section 194.171, barred any action to contest an assessment . . .
. . . more than a contest of a tax assessment, and that such an action was time barred pursuant to section 194.171 . . . unjust, capricious, arbitrary and illegal,” an action cognizable only under the strictures of section 194.171 . . . In maintaining that this action is also governed by the 60-day period provided in section 194.171(2), . . .
. . . Thereafter, the trust filed suit in circuit court pursuant to section 194.171, Florida Statutes (1991 . . .
. . . They argue that LRMC’s action was barred by section 194.171(2), Florida Statutes (1987) because neither . . . LRMC, nor its predecessor owner of the property, brought a timely action within the limits of section 194.171 . . . Section 194.171 provides in pertinent part as follows: (1) The circuit courts have original jurisdiction . . . We find no merit in LRMC’s argument that section 194.171 applies only to actions contesting tax assessments . . . the complaint filed by LRMC was not filed within the jurisdictional time limit set forth in section 194.171 . . .
. . . Florida Statutes §§ 194.171-194.231 (1993) provide a scheme to contest the imposition of taxes. . . . .
. . . prohibition because respondent FDIC did not comply with the jurisdictional requirements of section 194.171 . . . The sixty-day requirement of subsection 194.171(2) has been strictly enforced as a jurisdictional statute . . . Recognizing the clear and strict limitations of subsection 194.171(2), respondent FDIC has attempted . . . Section 194.171 is located in the chapter on administrative and judicial review of property taxes. . . . The jurisdictional limitations on challenges by a taxpayer to an assessment found in section 194.171 . . .
. . . The trial court concluded that the sixty-day statutory filing period under section 194.171(2), Florida . . . Section 194.171(2), Florida Statutes (1991) provides: (2) No action shall be brought to contest a tax . . . Section 194.171(6), Florida Statutes (1991) specifies that the “requirements of subsection (2) ... are . . .
. . . . § 194.171(2). . . . Section 194.171(2) of the Florida Statutes requires all actions contesting a tax assessment to be brought . . . Fla.Stat. § 194.171(6). . . .
. . . CPA challenged the assessment by filing suit pursuant to section 194.171, Florida Statutes (1991), against . . .
. . . See § 194.171(2), Fla.Stat. . . .
. . . contest the board’s action, so long as the taxpayer fulfills the jurisdictional requirements of section 194.171 . . . Alternatively, the taxpayer may directly seek a judicial remedy under section 194.171, so long as the . . . tax roll had been certified for collection, the circuit court lacked jurisdiction to hear the case. § 194.171 . . . The court also concluded that section 194.171(2), Florida Statutes, did not allow a challenge to the . . . denial of an application for exemption is not contesting a tax assessment within the meaning of section 194.171 . . . legislative intent and public policy behind adoption of the nonelaim provision contained in sections 194.171 . . . contest the board’s action, so long as the taxpayer fulfills the jurisdictional requirements of section 194.171 . . . Alternatively, the taxpayer may directly seek a judicial remedy under section 194.171, so long as the . . .
. . . However, the cited portion of section 194.171 relates to a challenge to a tax assessment. . . . Metropolitan Dade County, 231 So.2d 197 (Fla.1970) (construing predecessor to § 194.171); Millstream . . .
. . . the statutory notice provisions which trigger the running of the 60-day period contained in section 194.171 . . . Appellee filed a motion for summary judgment alleging that the challenge was untimely under section 194.171 . . . Sections 194.171(2) and (6), Florida Statutes, state in pertinent part: (2) No action shall be brought . . . Section 194.171(2), however, states that no action shall be brought “after 60 days from the date the . . . legislative intent and public policy behind the adoption of the nonclaim provision contained in sections 194.171 . . .
. . . . § 194.171, Fla.Stat. (1991). . . . The mere fact that section 194.171 proclaims that the circuit courts have original jurisdiction at law . . .