Florida Statute 194.171 - Full Text and Legal Analysis

The 2025 Florida Statutes

Title XIV
TAXATION AND FINANCE

Chapter 194
ADMINISTRATIVE AND JUDICIAL REVIEW OF PROPERTY TAXES

View Entire Chapter

F.S. 194.171

194.171 Circuit court to have original jurisdiction in tax cases.—

(1) The circuit courts have original jurisdiction at law of all matters relating to property taxation. Venue is in the county where the property is located, except that venue shall be in Leon County when the property is assessed pursuant to s. 193.085(4).

¹(2)(a) No action shall be brought to contest a tax assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122(2), or after 60 days from the date a decision is rendered concerning such assessment by the value adjustment board if a petition contesting the assessment had not received final action by the value adjustment board prior to extension of the roll under s. 197.323.

(b) Notwithstanding paragraph (a), the taxpayer that received a final action by the value adjustment board may bring an action within 30 days after recertification by the property appraiser under s. 193.122(3) if the roll was extended pursuant to s. 197.323.

(3) Before an action to contest a tax assessment may be brought, the taxpayer shall pay to the collector not less than the amount of the tax which the taxpayer admits in good faith to be owing. The collector shall issue a receipt for the payment, and the receipt shall be filed with the complaint. Notwithstanding the provisions of chapter 197, payment of the taxes the taxpayer admits to be due and owing and the timely filing of an action pursuant to this section shall suspend all procedures for the collection of taxes prior to final disposition of the action.

(4) Payment of a tax shall not be deemed an admission that the tax was due and shall not prejudice the right to bring a timely action as provided in subsection (2) to challenge such tax and seek a refund.

(5) No action to contest a tax assessment may be maintained, and any such action shall be dismissed, unless all taxes on the property assessed in years after the action is brought, which the taxpayer in good faith admits to be owing, are paid before they become delinquent.

(6) The requirements of subsections (2), (3), and (5) are jurisdictional. No court shall have jurisdiction in such cases until after the requirements of both subsections (2) and (3) have been met. A court shall lose jurisdiction of a case when the taxpayer has failed to comply with the requirements of subsection (5).

History.—s. 1, ch. 8586, 1921; CGL 1038; s. 2, ch. 29737, 1955; s. 1, ch. 67-538; ss. 1, 2, ch. 69-55; s. 8, ch. 69-102; s. 6, ch. 69-140; ss. 30, 31, ch. 70-243; s. 1, ch. 72-239; s. 6, ch. 74-234; s. 17, ch. 82-226; s. 7, ch. 83-204; s. 56, ch. 83-217; s. 211, ch. 85-342; s. 3, ch. 88-146; s. 151, ch. 91-112; s. 32, ch. 94-353; s. 1470, ch. 95-147; s. 11, ch. 2025-208.

¹Note.—Section 12, ch. 2025-208, provides that “[t]he amendments made by this act to s. 194.171, Florida Statutes, first apply to the 2026 tax roll.”

Note.—Former ss. 192.21, 194.151, 196.01.

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Amendments to 194.171

Annotations, Discussions, Cases:

Cases Citing Statute 194.171

Total Results: 203

Allen v. Butterworth

756 So. 2d 52, 2000 WL 381484

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

Cited 53 times | Published

(1962). The circuit court also concluded that section 194.171(2), Florida Statutes (1975), which provided

Zingale v. Powell

885 So. 2d 277, 2004 WL 2050106

Supreme Court of Florida | Filed: Sep 15, 2004 | Docket: 1685210

Cited 43 times | Published

appraisers, and the sixty-day deadline in section 194.171(2), Florida Statutes (2001), for a civil complaint

Cason v. FLORIDA DEPT. OF MANAGEMENT SERVS.

944 So. 2d 306, 2006 WL 3313749

Supreme Court of Florida | Filed: Nov 16, 2006 | Docket: 2518596

Cited 30 times | Published

THE JURISDICTIONAL NON-CLAIM PROVISIONS OF SECTION 194.171, FLORIDA STATUTES, APPLY TO BAR A CLAIM OF

Markham v. Neptune Hollywood Beach Club

527 So. 2d 814, 13 Fla. L. Weekly 423, 1988 Fla. LEXIS 795, 1988 WL 70702

Supreme Court of Florida | Filed: Jul 7, 1988 | Docket: 1526087

Cited 23 times | Published

not filed within the sixty-day limitation of section 194.171(2), Florida Statutes (1983). Respondents are

Bystrom v. Diaz

514 So. 2d 1072, 12 Fla. L. Weekly 462

Supreme Court of Florida | Filed: Sep 10, 1987 | Docket: 1466882

Cited 21 times | Published

before they became delinquent as required by section 194.171(5). The Third District Court of Appeal, in

GBB Investments, Inc. v. Hinterkopf

343 So. 2d 899

District Court of Appeal of Florida | Filed: Mar 1, 1977 | Docket: 1710584

Cited 21 times | Published

assessment against him claimed to be excessive. Section 194.171(3)(4), Florida Statutes (1975). Millstream

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

upon a $37,000,000 valuation as required by Section 194.171(4), supra.[12] The trial court determined the

Reinish v. Clark

765 So. 2d 197, 2000 WL 991017

District Court of Appeal of Florida | Filed: Jul 20, 2000 | Docket: 1522951

Cited 17 times | Published

circumvent the jurisdictional requirements of section 194.171, Florida Statutes (1997), by seeking relief

Markham v. Moriarty

575 So. 2d 1307, 1991 WL 11664

District Court of Appeal of Florida | Filed: Feb 6, 1991 | Docket: 1443425

Cited 16 times | Published

the 60 days allowed for filing pursuant to section 194.171(2), Florida Statutes (1989). The tax roll was

In Re Piper Aircraft Corp.

171 B.R. 415, 32 Collier Bankr. Cas. 2d 1057, 8 Fla. L. Weekly Fed. B 159, 1994 Bankr. LEXIS 1335, 25 Bankr. Ct. Dec. (CRR) 1672

United States Bankruptcy Court, S.D. Florida. | Filed: Aug 31, 1994 | Docket: 1458475

Cited 15 times | Published

assessments, as required under state law. Fl.Stat. § 194.171(2).[3] On February 18, 1994, Piper filed its 505

District School Board of Lee County v. Askew

278 So. 2d 272

Supreme Court of Florida | Filed: Apr 4, 1973 | Docket: 1356178

Cited 15 times | Published

assessment is through the circuit court (Fla. Stat. § 194.171, F.S.A.), and the State has the power, through

ITT Community Development Corp. v. Seay

347 So. 2d 1024

Supreme Court of Florida | Filed: Jun 30, 1977 | Docket: 1415885

Cited 14 times | Published

reviewing the propriety of an assessment (Section 194.171, Florida Statutes). The mandate of the Florida

Ward v. Brown

894 So. 2d 811, 2004 WL 2360129

Supreme Court of Florida | Filed: Oct 21, 2004 | Docket: 2516600

Cited 12 times | Published

that the mandatory sixty-day provision of section 194.171(1), Florida Statutes, applies broadly to taxpayers'

Chihocky v. Crapo

632 So. 2d 230, 1994 WL 47118

District Court of Appeal of Florida | Filed: Feb 18, 1994 | Docket: 462623

Cited 12 times | Published

running of the 60-day period contained in section 194.171(2), Florida Statutes. We also find that the

Matter of East Coast Brokers & Packers, Inc.

142 B.R. 499, 6 Fla. L. Weekly Fed. B 166, 1992 Bankr. LEXIS 1012, 23 Bankr. Ct. Dec. (CRR) 262, 1992 WL 159868

United States Bankruptcy Court, M.D. Florida | Filed: Jul 9, 1992 | Docket: 1635373

Cited 12 times | Published

debtor's tax liability and the provisions of Section 194.171(2) of the Florida Statutes limiting the time

United States v. Broward County, Florida, William Markham, Broward County Appraiser, Joseph E. Rosenhagen, Broward County Revenue Collector

901 F.2d 1005, 1990 U.S. App. LEXIS 8235, 1990 WL 56513

Court of Appeals for the Eleventh Circuit | Filed: May 21, 1990 | Docket: 825109

Cited 12 times | Published

Government of the United States. 2 . Section 194.171 Florida Statutes (1987) provides in pertinent

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

an action in the circuit court pursuant to section 194.171, Florida Statutes. Ch. 74-234, § 6, Laws of

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

an action in the circuit court pursuant to section 194.171, Florida Statutes. Ch. 74-234, § 6, Laws of

Prewitt Management Corp. v. Nikolits

795 So. 2d 1001, 2001 WL 914104

District Court of Appeal of Florida | Filed: Aug 15, 2001 | Docket: 1673127

Cited 11 times | Published

for lack of subject matter jurisdiction. See § 194.171, Fla. Stat. (1997); Nikolits v. Delaney, 719 So

Florida E. Coast Ry. Co. v. Dept. of Rev.

620 So. 2d 1051, 1993 WL 210590

District Court of Appeal of Florida | Filed: Jun 18, 1993 | Docket: 1722662

Cited 10 times | Published

court was invoked under the provisions of section 194.171, Florida Statutes (1987). In its complaints

Walker v. Garrison

610 So. 2d 716, 1992 WL 379900

District Court of Appeal of Florida | Filed: Dec 23, 1992 | Docket: 1734945

Cited 10 times | Published

clear. The 60 day filing period referred to in section 194.171 is 60 days from the date of the initial certification

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

Defendant, Valencia, counterclaimed under Section 194.171, Florida Statutes (1979), claiming that the

Williams v. Law

368 So. 2d 1285

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

Cited 10 times | Published

Court for Pasco County, Florida, invalidating section 194.171(2), Florida Statutes (1975), as it relates

State, Dept. of Revenue v. Stafford

646 So. 2d 803, 1994 WL 685951

District Court of Appeal of Florida | Filed: Dec 7, 1994 | Docket: 1713356

Cited 9 times | Published

comply with the jurisdictional requirements of section 194.171, Florida Statutes (1993), governing challenges

North Port Bank v. State, Department of Revenue

313 So. 2d 683, 1975 Fla. LEXIS 3316

Supreme Court of Florida | Filed: Apr 16, 1975 | Docket: 1509585

Cited 9 times | Published

alternative, i.e., the procedure established by Section 194.171 (4) and Section 194.192(2), Florida Statutes

Askew v. MGIC Development Corporation of Florida

262 So. 2d 227

District Court of Appeal of Florida | Filed: Apr 4, 1972 | Docket: 429083

Cited 9 times | Published

Circuit Court pursuant to the provisions of Section 194.171, F.S. 1969, F.S.A., ask us to review an order

Miller v. Nolte

453 So. 2d 397

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

Cited 8 times | Published

other things, that the statute of limitations, section 194.171(2), Florida Statutes (1981), prohibited taxpayer's

Village of Doral Place Ass'n v. RU4 Real, Inc.

22 So. 3d 627, 2009 Fla. App. LEXIS 15540, 2009 WL 3271164

District Court of Appeal of Florida | Filed: Oct 14, 2009 | Docket: 1639703

Cited 7 times | Published

was barred by the tax non-claim statute. See § 194.171(2), Fla. Stat. (2003). The court granted declaratory

Davis v. MacEdonia Housing Authority

641 So. 2d 131, 1994 WL 284111

District Court of Appeal of Florida | Filed: Jun 29, 1994 | Docket: 1648423

Cited 7 times | Published

fulfills the jurisdictional requirements of section 194.171 by filing the action within 60 days after the

Blake v. RMS Holding Corp.

341 So. 2d 795

District Court of Appeal of Florida | Filed: Jan 18, 1977 | Docket: 1393986

Cited 7 times | Published

in the circuit court of Dade County, under Section 194.171 Florida Statutes (1973), contesting the amount

Willens v. Garcia

53 So. 3d 1113, 2011 Fla. App. LEXIS 533, 2011 WL 222150

District Court of Appeal of Florida | Filed: Jan 26, 2011 | Docket: 60297992

Cited 6 times | Published

appraiser before the value adjustment board. See § 194.171(1), Fla. Stat. (2008); Deluccio v. Havill, 25

Dept. of Revenue v. Canaveral Port Auth.

642 So. 2d 1097, 1994 Fla. App. LEXIS 8248, 1994 WL 444886

District Court of Appeal of Florida | Filed: Aug 19, 1994 | Docket: 549227

Cited 6 times | Published

the assessment by filing suit pursuant to section 194.171, Florida Statutes (1991), against Brevard County's

Hirsh v. Crews

494 So. 2d 260, 11 Fla. L. Weekly 1920

District Court of Appeal of Florida | Filed: Sep 9, 1986 | Docket: 452425

Cited 6 times | Published

within the 60-day claims period provided under section 194.171(2), Florida Statutes, commenced the action

Clark v. Cook

481 So. 2d 929, 10 Fla. L. Weekly 2630

District Court of Appeal of Florida | Filed: Nov 27, 1985 | Docket: 548890

Cited 6 times | Published

co-petitioners. The issue is not complex. Section 194.171, Florida Statutes (1983), is clear to us, saying:

GULFSIDE INTERVAL VACS., INC. v. Schultz

479 So. 2d 776, 10 Fla. L. Weekly 2562

District Court of Appeal of Florida | Filed: Nov 13, 1985 | Docket: 463531

Cited 6 times | Published

impression, we consider the application of section 194.171(6), Florida Statutes (1983), as a bar to a

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

tax assessment, alleging jurisdiction under Section 194.171, Florida Statutes (1979). Appellees moved to

SCHOOL BD. OF MARION COUNTY v. Angel

404 So. 2d 359

District Court of Appeal of Florida | Filed: May 13, 1981 | Docket: 1782234

Cited 6 times | Published

to dismiss the complaint on the ground that section 194.171, Florida Statutes (1979), provides that an

Lanning v. Pilcher

16 So. 3d 294, 2009 Fla. App. LEXIS 13118, 2009 WL 2605426

District Court of Appeal of Florida | Filed: Aug 26, 2009 | Docket: 1641193

Cited 5 times | Published

the case for lack of jurisdiction, because section 194.171, Florida Statutes, requires that an action

STATE, DEPT., REVENUE v. Gerald Sohn

654 So. 2d 249, 1995 WL 238763

District Court of Appeal of Florida | Filed: Apr 26, 1995 | Docket: 1710342

Cited 5 times | Published

such an action was time barred pursuant to section 194.171, Florida Statutes, because it had not been

Hall v. Leesburg Regional Medical Center

651 So. 2d 231, 1995 Fla. App. LEXIS 2068, 1995 WL 84471

District Court of Appeal of Florida | Filed: Mar 3, 1995 | Docket: 476431

Cited 5 times | Published

They argue that LRMC's action was barred by section 194.171(2), Florida Statutes (1987) because neither

Markham v. Hinckley

544 So. 2d 1139, 1989 WL 62424

District Court of Appeal of Florida | Filed: Jun 14, 1989 | Docket: 1301242

Cited 5 times | Published

Bond's suit which was brought pursuant to section 194.171, Florida Statutes (1985), to contest a 1986

Oyster Pointe Resort Condo. v. Nolte

524 So. 2d 415

Supreme Court of Florida | Filed: Mar 31, 1988 | Docket: 1701555

Cited 5 times | Published

tax assessment is through the circuit court. § 194.171, Fla. Stat. (1983). We decline to address this

Marshall v. Perkins

494 So. 2d 506, 11 Fla. L. Weekly 1801

District Court of Appeal of Florida | Filed: Aug 13, 1986 | Docket: 452361

Cited 5 times | Published

become delinquent. In its pertinent parts, section 194.171, Florida Statutes (1983), the controlling statute

Mikos v. Ringling Bros.-Barnum & Bailey

475 So. 2d 292, 10 Fla. L. Weekly 2138

District Court of Appeal of Florida | Filed: Sep 13, 1985 | Docket: 1302206

Cited 5 times | Published

not the evaluation of assessment of property. § 194.171(3), Fla. Stat. Nor was appellant entitled to a

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

means of judicial review in the circuit court (Section 194.171, Florida Statutes (1981)). Section 194.181

Muckenfuss v. Miller

421 So. 2d 170

District Court of Appeal of Florida | Filed: Sep 29, 1982 | Docket: 1719238

Cited 5 times | Published

into the registry of the court, pursuant to section 194.171, Florida Statutes (1981). The court ruled that

Muckenfuss v. Miller

421 So. 2d 170

District Court of Appeal of Florida | Filed: Sep 29, 1982 | Docket: 1719238

Cited 5 times | Published

into the registry of the court, pursuant to section 194.171, Florida Statutes (1981). The court ruled that

Underhill v. Edwards

400 So. 2d 129

District Court of Appeal of Florida | Filed: Jun 17, 1981 | Docket: 1677231

Cited 5 times | Published

of the contested assessment as required by section 194.171(2), Florida Statutes (1977), citing Coe v.

Coe v. ITT Community Development Corp.

362 So. 2d 8, 1978 Fla. LEXIS 4866

Supreme Court of Florida | Filed: Jul 20, 1978 | Docket: 1363033

Cited 5 times | Published

filed within the 60-day period prescribed by Section 194.171(2), Florida Statutes (1975).[2] Recognizing

Thomas v. Smith

882 So. 2d 1037, 2004 WL 1824123

District Court of Appeal of Florida | Filed: Aug 13, 2004 | Docket: 1289555

Cited 4 times | Published

Taxpayers were barred by the nonclaim statute in section 194.171(6), Florida Statutes (1997). The Tax Collector

Department of Rev. v. Eastern American Technologies Corp.

762 So. 2d 1044, 2000 Fla. App. LEXIS 9476, 2000 WL 1033038

District Court of Appeal of Florida | Filed: Jul 28, 2000 | Docket: 1311497

Cited 4 times | Published

valorem taxes within sixty days, as mandated by section 194.171(2), Florida Statutes (1999).[1] The Brevard

Sartori v. Department of Revenue

714 So. 2d 1136, 1998 WL 396717

District Court of Appeal of Florida | Filed: Jul 17, 1998 | Docket: 205814

Cited 4 times | Published

and Sartori missed the sixty-day deadline. Section 194.171 provides, in relevant part: 194.171 Circuit

Pogge v. Department of Revenue

703 So. 2d 523, 1997 WL 791693

District Court of Appeal of Florida | Filed: Dec 30, 1997 | Docket: 1349330

Cited 4 times | Published

suit for refund. The Department analogizes to section 194.171, Florida Statutes. In Markham v. Neptune Hollywood

Countryside Country Club, Inc. v. Smith

573 So. 2d 14, 1990 WL 172842

District Court of Appeal of Florida | Filed: Nov 9, 1990 | Docket: 1518830

Cited 4 times | Published

circuit court has jurisdiction, pursuant to section 194.171, Florida Statutes (1987), to establish just

Fredericks v. Blake

382 So. 2d 368

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

Cited 4 times | Published

file suit in circuit court as provided by Section 194.171, Florida Statutes (1977). There are additional

Millstream Corp. v. Dade County

340 So. 2d 1276, 1977 Fla. App. LEXIS 15025

District Court of Appeal of Florida | Filed: Jan 4, 1977 | Docket: 1299123

Cited 4 times | Published

latter's failure to comply with Florida Statutes § 194.171(3) & (4) (Supp. 1976), which require a taxpayer

Hollywood Jaycees v. State, Department of Revenue

306 So. 2d 109

Supreme Court of Florida | Filed: Nov 20, 1974 | Docket: 1720524

Cited 4 times | Published

judicial review de novo in the Circuit Court. Section 194.171, F.S. However, such review does not supply

DADE CTY v. Transportes Aereos Nacionales, SA

298 So. 2d 570

District Court of Appeal of Florida | Filed: Jun 28, 1974 | Docket: 1439205

Cited 4 times | Published

collection (on October 3, 1972) as required by § 194.171(2), Fla. Stat., and (2) the complaint fails to

Monroe County v. Gustinger

285 So. 2d 431

District Court of Appeal of Florida | Filed: Nov 13, 1973 | Docket: 141433

Cited 4 times | Published

administrative remedies and bring his suit, as provided in § 194.171, Fla. Stat., F.S.A. We find this point to be well

Miles v. Parrish

199 So. 3d 1046, 2016 Fla. App. LEXIS 10777, 41 Fla. L. Weekly Fed. D 1614

District Court of Appeal of Florida | Filed: Jul 13, 2016 | Docket: 60256533

Cited 3 times | Published

beyond the sixty-day statute of non-claim under section 194.171, Florida Statutes. We find this was error and

In Re Read

442 B.R. 839, 22 Fla. L. Weekly Fed. B 717, 2011 Bankr. LEXIS 132, 54 Bankr. Ct. Dec. (CRR) 54, 2011 WL 180085

United States Bankruptcy Court, M.D. Florida | Filed: Jan 19, 2011 | Docket: 2065885

Cited 3 times | Published

192.053, and 197.122 (2008). [3] Fla. Stat. § 194.171(2) (2009). [4] Response to Debtor's Objection

Tarpon Springs Hospital Foundation, Inc. v. Anderson

34 So. 3d 742, 2010 Fla. App. LEXIS 5257, 2010 WL 1563544

District Court of Appeal of Florida | Filed: Apr 21, 2010 | Docket: 1641416

Cited 3 times | Published

"taxpayer" as used in section 194.171, Florida Statutes (2006). Because section 194.171 did not define "taxpayer

Bruner v. Hartsfield

23 So. 3d 192, 2009 Fla. App. LEXIS 17266, 2009 WL 3818216

District Court of Appeal of Florida | Filed: Nov 17, 2009 | Docket: 1181838

Cited 3 times | Published

appellants/cross-appellees' failure to comply with section 194.171(1), Florida Statutes, this issue is governed

Page v. McMullan

849 So. 2d 15, 2003 WL 1204107

District Court of Appeal of Florida | Filed: Mar 18, 2003 | Docket: 447594

Cited 3 times | Published

assessment was not timely filed in accordance with section 194.171(2). The trial court granted leave to amend

Ward v. Brown

892 So. 2d 1059, 2003 WL 1088219

District Court of Appeal of Florida | Filed: Mar 13, 2003 | Docket: 1517052

Cited 3 times | Published

barred from bringing an action pursuant to section 194.171(1), Florida Statutes, challenging a property

GOVERNMENTAL UTILITY AUTHORITY v. Day

784 So. 2d 494, 2001 WL 303239

District Court of Appeal of Florida | Filed: Mar 30, 2001 | Docket: 1744206

Cited 3 times | Published

alleging the complaint was untimely based on section 194.171(2), which provides: No action shall be brought

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

Delaney, 719 So.2d 348 (Fla. 4th DCA 1998). Section 194.171(2), Florida Statutes (1997) provides that "[n]o

Nikolits v. Delaney

719 So. 2d 348, 1998 WL 670421

District Court of Appeal of Florida | Filed: Oct 1, 1998 | Docket: 748265

Cited 3 times | Published

action to contest a tax assessment governed by section 194.171, Florida Statutes (1997). Since respondents'

Washington Square Corp. v. Wright

687 So. 2d 1374, 1997 WL 75479

District Court of Appeal of Florida | Filed: Feb 25, 1997 | Docket: 1370993

Cited 3 times | Published

taxpayer admits in good faith to be owing." Section 194.171, Florida Statutes (1995), provides: (3) Before

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

to be owing before they become delinquent. Section 194.171(4), Florida Statutes (1979). We further note

Malibu Partners, Ltd. v. Schooley

372 So. 2d 179, 1979 Fla. App. LEXIS 14852

District Court of Appeal of Florida | Filed: Jun 15, 1979 | Docket: 1695536

Cited 3 times | Published

assessment of the property for tax purposes. Section 194.171(2), Florida Statutes (1977), provides that

Hilltop Ranch, Inc. v. Brown

308 So. 2d 124

District Court of Appeal of Florida | Filed: Feb 25, 1975 | Docket: 1251352

Cited 3 times | Published

complaint did not show a compliance with F.S. § 194.171. Essentially, this appeal involves one question:

Walden v. University of Tampa, Incorporated

304 So. 2d 134

District Court of Appeal of Florida | Filed: Dec 11, 1974 | Docket: 1437438

Cited 3 times | Published

similar in language to the present statute Section 194.171(2). This latter section provides: No action

Genesis Ministries, Inc. v. Gregory S. Brown, as Property etc.

250 So. 3d 865

District Court of Appeal of Florida | Filed: Jul 25, 2018 | Docket: 7510959

Cited 2 times | Published

certification of the tax rolls as required under section 194.171(2), Florida Statutes (2013). Genesis appealed

Genesis Ministries, Inc. v. Gregory S. Brown, as Property etc.

186 So. 3d 1074, 2016 WL 606685

District Court of Appeal of Florida | Filed: Feb 15, 2016 | Docket: 3036262

Cited 2 times | Published

in finding that its challenge was barred by section 194.171(2), Florida Statutes. We agree. Accordingly

Nikolits v. Hanna

92 So. 3d 299, 2012 WL 2913295, 2012 Fla. App. LEXIS 11703

District Court of Appeal of Florida | Filed: Jul 18, 2012 | Docket: 60310210

Cited 2 times | Published

comply with the requirements of subsection (5). § 194.171(5) & (6), Fla. Stat. (2011). The trial court denied

1108 ARIOLA, LLC v. Jones

71 So. 3d 892, 2011 Fla. App. LEXIS 11178, 2011 WL 2752686

District Court of Appeal of Florida | Filed: Jul 18, 2011 | Docket: 2360109

Cited 2 times | Published

have been placed on any of the property since section 194.171, Florida Statutes, imposes a stay on the collection

Milan Investment Group, Inc. v. City of Miami

50 So. 3d 662, 2010 Fla. App. LEXIS 18004, 2010 WL 4740293

District Court of Appeal of Florida | Filed: Nov 24, 2010 | Docket: 60297331

Cited 2 times | Published

confirm the applicability of the non-claim statute, § 194.171, to that challenge. Our reversal permitting the

Taylor v. City of Lake Worth

964 So. 2d 243, 2007 Fla. App. LEXIS 13844, 2007 WL 2480785

District Court of Appeal of Florida | Filed: Sep 5, 2007 | Docket: 64852144

Cited 2 times | Published

that the sixty-day filing period specified in section 194.171, Florida Statutes, had expired and could not

Taylor v. City of Lake Worth

964 So. 2d 243, 2007 Fla. App. LEXIS 13844, 2007 WL 2480785

District Court of Appeal of Florida | Filed: Sep 5, 2007 | Docket: 64852144

Cited 2 times | Published

that the sixty-day filing period specified in section 194.171, Florida Statutes, had expired and could not

Hidden Bay Master Association, Inc. v. Miami-Dade County Department of Property Appraisal

938 So. 2d 599, 2006 WL 2741632

District Court of Appeal of Florida | Filed: Sep 27, 2006 | Docket: 1673733

Cited 2 times | Published

ground that the sixty-day statute of non-claim, section 194.171(2), Florida Statutes (2001), expired.[3] On

STATE DEPT. OF MANAGEMENT SERVICES v. Cason

909 So. 2d 378

District Court of Appeal of Florida | Filed: Aug 4, 2005 | Docket: 1199740

Cited 2 times | Published

certification for collection, as required by section 194.171(2), Florida Statutes (2000). Because we conclude

Gilreath v. General Elec. Co.

751 So. 2d 705, 2000 Fla. App. LEXIS 1135, 2000 WL 145956

District Court of Appeal of Florida | Filed: Feb 11, 2000 | Docket: 1310195

Cited 2 times | Published

was thereafter commenced in accordance with Section 194.171, Florida Statutes. E. In 1993, the Property

Bankunited Financial Corp. v. Markham

763 So. 2d 1072, 1999 WL 767399

District Court of Appeal of Florida | Filed: Sep 29, 1999 | Docket: 1278384

Cited 2 times | Published

certification of the tax rolls as required by section 194.171, the appraiser alleged that the court lacked

Nana's Petroleum, Inc. v. Clark (In Re Nana's Petroleum, Inc.)

234 B.R. 838, 12 Fla. L. Weekly Fed. B 216, 42 Collier Bankr. Cas. 2d 233, 1999 Bankr. LEXIS 632, 34 Bankr. Ct. Dec. (CRR) 492

United States Bankruptcy Court, S.D. Florida. | Filed: May 3, 1999 | Docket: 1677877

Cited 2 times | Published

Furthermore, DOR asserts that by failing to comply with § 194.171, Florida Statutes, which requires timely challenges

Metropolitan Dade County v. Kapila (In Re Home & Housing of Dade County, Inc.)

220 B.R. 492, 1998 WL 199342

District Court, S.D. Florida | Filed: Apr 28, 1998 | Docket: 1783613

Cited 2 times | Published

to contest a tax assessment, set forth in Section 194.171(2), Fla.Stat., is not at issue in this case

Keenan v. City of Edgewater

684 So. 2d 226, 1996 Fla. App. LEXIS 12301, 1996 WL 672985

District Court of Appeal of Florida | Filed: Nov 22, 1996 | Docket: 1740916

Cited 2 times | Published

days from the date the assessment is certified. § 194.171(2), Fla. Stat. (1995). Earlier cases involving

State, Dept. of Revenue v. Ray Const.

667 So. 2d 859, 1996 Fla. App. LEXIS 537, 1996 WL 31884

District Court of Appeal of Florida | Filed: Jan 30, 1996 | Docket: 1511579

Cited 2 times | Published

Chihocky, the pertinent statutory provision, section 194.171, barred any action to contest an assessment

Wilkinson v. Kirby

654 So. 2d 194, 1995 WL 228274

District Court of Appeal of Florida | Filed: Apr 19, 1995 | Docket: 1303644

Cited 2 times | Published

trust filed suit in circuit court pursuant to section 194.171, Florida Statutes (1991). After conducting

Joyner v. Roberts

642 So. 2d 826, 1994 WL 513536

District Court of Appeal of Florida | Filed: Sep 22, 1994 | Docket: 550005

Cited 2 times | Published

the sixty-day statutory filing period under section 194.171(2), Florida Statutes (1991) began to run when

Robbins v. Friedman

625 So. 2d 83, 1993 WL 392688

District Court of Appeal of Florida | Filed: Sep 28, 1993 | Docket: 20401

Cited 2 times | Published

exercise jurisdiction over the contest because of section 194.171(5), (6), Florida Statutes (1991). The taxpayers

Robbins v. Section 3 Property Corp.

609 So. 2d 670, 1992 Fla. App. LEXIS 11779, 1992 WL 353381

District Court of Appeal of Florida | Filed: Nov 24, 1992 | Docket: 1473846

Cited 2 times | Published

from selling the property to collect taxes). Section 194.171, Florida Statutes (1991), grants original jurisdiction

Wilkinson v. Reese

540 So. 2d 141, 14 Fla. L. Weekly 591, 1989 Fla. App. LEXIS 1063, 1989 WL 17238

District Court of Appeal of Florida | Filed: Mar 3, 1989 | Docket: 64641133

Cited 2 times | Published

Feinsteins filed a complaint, pursuant to section 194.171, Florida Statutes (1987), against the petitioners

Bonavista Condominium Ass'n v. Bystrom

520 So. 2d 84, 1988 WL 10221

District Court of Appeal of Florida | Filed: Feb 16, 1988 | Docket: 1300332

Cited 2 times | Published

property involved in the suit as required by section 194.171, Florida Statutes (1985). We note that in its

Seitlin v. Bystrom

514 So. 2d 368

District Court of Appeal of Florida | Filed: Nov 3, 1987 | Docket: 1466880

Cited 2 times | Published

the decision of the board. (Emphasis added.) Section 194.171(2), Florida Statutes (1985): 194.171 Circuit

Diaz v. Bystrom

487 So. 2d 1112, 11 Fla. L. Weekly 830

District Court of Appeal of Florida | Filed: Apr 8, 1986 | Docket: 1797649

Cited 2 times | Published

1982 assessment. The statute in question is section 194.171, Florida Statutes (1985), which provides in

Neptune Hollywood Beach Club, Inc. v. Markham

473 So. 2d 691, 10 Fla. L. Weekly 657

District Court of Appeal of Florida | Filed: Mar 13, 1985 | Docket: 451612

Cited 2 times | Published

after the sixty-day limitation period which section 194.171(2), *692 Florida Statutes (1983), imposes on

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

no subject matter jurisdiction pursuant to Section 194.171(2), Florida Statutes (1981), (2) as to parcels

City of Miami v. Florida Retail Federation, Inc.

423 So. 2d 991

District Court of Appeal of Florida | Filed: Dec 28, 1982 | Docket: 1389102

Cited 2 times | Published

notice to the tax collector of a contest under section 194.171, Florida Statutes (1975), governing ad valorem

Willig v. Blake

358 So. 2d 871

District Court of Appeal of Florida | Filed: May 16, 1978 | Docket: 1690840

Cited 2 times | Published

payment of taxes upon an assessment in dispute. Section 194.171, Florida Statutes (1975), establishes the procedure

Brooks v. INTERLACHEN LAKES ESTATES

332 So. 2d 681

District Court of Appeal of Florida | Filed: May 18, 1976 | Docket: 1314291

Cited 2 times | Published

dismissed without leave to amend. Pursuant to § 194.171, Florida Statutes, appellees filed a complaint

Slay v. Department of Revenue

317 So. 2d 744

Supreme Court of Florida | Filed: Jul 31, 1975 | Docket: 1316116

Cited 2 times | Published

away with a lot of things I can't." [10] Section 194.171(1), Fla. Stat. (1973). [11] Fla.R.Civ.Proc

Edward A. Crapo, as Alachua County etc. v. Provident Group - Continuum etc.

238 So. 3d 869

District Court of Appeal of Florida | Filed: Feb 7, 2018 | Docket: 6299303

Cited 1 times | Published

assessment and is not barred by the time limit of section 194.171(2). Thereafter, Appellee filed a second

Forest Brooke/Hillsborough, LLC v. Henriquez

194 So. 3d 1091, 2016 Fla. App. LEXIS 9971, 2016 WL 3541045

District Court of Appeal of Florida | Filed: Jun 29, 2016 | Docket: 3088981

Cited 1 times | Published

filed, it subsequently lost jurisdiction under section 194.171,’ Florida Statutes (2009), when Forest Brooke

American Heritage Window Fashions, LLC v. Department of Revenue

191 So. 3d 516, 2016 WL 2609522, 2016 Fla. App. LEXIS 6983

District Court of Appeal of Florida | Filed: May 6, 2016 | Docket: 3061538

Cited 1 times | Published

1988) (holding that analogous language in section 194.171, Florida Statutes, setting time limitations

Gary R. Nikolits, as Property Appraiser for Palm Beach County, Florida v. Sarah B. Neff a/k/a Susan B. Neff a/k/a Sally B. Neff

184 So. 3d 538, 2015 Fla. App. LEXIS 18399, 2015 WL 8348320

District Court of Appeal of Florida | Filed: Dec 9, 2015 | Docket: 3019348

Cited 1 times | Published

the 2012 assessment of her former homestead. Section 194.171(2), Florida Statutes (2012), is a jurisdictional

Milan Investment Group, Inc. v. City of Miami

172 So. 3d 458, 2015 Fla. App. LEXIS 7997

District Court of Appeal of Florida | Filed: May 27, 2015 | Docket: 2659838

Cited 1 times | Published

the sixty-day non-claim statute pursuant to section 194.171(2), Florida Statutes (except for the current

Provident Group-Continuum Properties, L.L.C. Ex Rel. University of Florida v. Crapo

157 So. 3d 409

District Court of Appeal of Florida | Filed: Feb 2, 2015 | Docket: 2630635

Cited 1 times | Published

the complaint for lack of jurisdiction under section 194.171(2), Florida Statutes (2013), a statute of non-claim

Wilkinson v. Clarke

91 So. 3d 897, 2012 WL 3055442, 2012 Fla. App. LEXIS 10584

District Court of Appeal of Florida | Filed: Jun 29, 2012 | Docket: 60310008

Cited 1 times | Published

lost jurisdiction over the case pursuant to section 194.171, Florida Statutes (2010). At the hearing on

South Pointe Family & Children Center, Inc. v. Miami-Dade County

57 So. 3d 256, 2011 Fla. App. LEXIS 3498, 2011 WL 904277

District Court of Appeal of Florida | Filed: Mar 16, 2011 | Docket: 2361310

Cited 1 times | Published

exempt from the jurisdictional requirements of section 194.171, Florida Statutes (2007), the Non-Claim Statute

Bennett v. Wells

55 So. 3d 666, 2011 Fla. App. LEXIS 1988, 36 Fla. L. Weekly Fed. D 391

District Court of Appeal of Florida | Filed: Feb 18, 2011 | Docket: 2407919

Cited 1 times | Published

Mr. Bennett filed his lawsuit pursuant to section 194.171, Florida Statutes (2008), challenging the denial

Deluccio v. Havill

25 So. 3d 31, 2009 Fla. App. LEXIS 17151

District Court of Appeal of Florida | Filed: Nov 17, 2009 | Docket: 60287593

Cited 1 times | Published

jurisdiction when appellants did not comply with section 194.171(1), Florida Statutes, we reverse on the authority

Deluccio v. Havill

25 So. 3d 31, 2009 WL 3817905

District Court of Appeal of Florida | Filed: Nov 17, 2009 | Docket: 1933475

Cited 1 times | Published

jurisdiction when appellants did not comply with section 194.171(1), Florida Statutes, we reverse on the authority

Higgs v. ARMADA KEY WEST LTD. PARTNERSHIP

903 So. 2d 303, 2005 WL 1345433

District Court of Appeal of Florida | Filed: Jun 8, 2005 | Docket: 1675331

Cited 1 times | Published

assessment. For the following reasons, we agree. Section 194.171 of the Florida Statutes confers jurisdiction

Higgs v. Klock

873 So. 2d 591, 2004 Fla. App. LEXIS 7357, 2004 WL 1161740

District Court of Appeal of Florida | Filed: May 26, 2004 | Docket: 64830709

Cited 1 times | Published

pay the 2000 and 2001 taxes as required by section 194.171(5), Florida Statutes (2002). See Bystrom v

Crapo v. City of Gainesville

855 So. 2d 203, 2003 WL 22142534

District Court of Appeal of Florida | Filed: Sep 18, 2003 | Docket: 2560679

Cited 1 times | Published

the 60 day statute of nonclaim set forth in section 194.171(2), Florida Statutes (2001). The trial court

Todora v. Venice Golf Ass'n, Inc.

847 So. 2d 577, 2003 WL 21394455

District Court of Appeal of Florida | Filed: Jun 18, 2003 | Docket: 1686747

Cited 1 times | Published

within the sixty-day period prescribed by section 194.171(2), Florida Statutes (1999). Because we conclude

Primeco Personal Communications, L.P. v. Mastroianni

837 So. 2d 1157, 2003 Fla. App. LEXIS 2006, 2003 WL 367068

District Court of Appeal of Florida | Filed: Feb 21, 2003 | Docket: 64820882

Cited 1 times | Published

v. Friedman, 625 So.2d 83 (Fla. 3d DCA 1993); § 194.171(6), Fla. Stat. (2002). We agree with Mastroianni

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

located in Osceola County was untimely under section 194.171, Florida Statutes (1997). This statute provides

In Re Psychiatric Hospitals of Florida Inc.

217 B.R. 645, 11 Fla. L. Weekly Fed. B 195, 1997 Bankr. LEXIS 2171, 1997 WL 828292

United States Bankruptcy Court, M.D. Florida | Filed: Apr 28, 1997 | Docket: 1499055

Cited 1 times | Published

determination by the Board. Florida Statutes § 194.171 provides for a judicial review of the determination

Brazilian Court Hotel Condominium Owners Ass'n, Inc. v. Walker

584 So. 2d 609, 1991 WL 147667

District Court of Appeal of Florida | Filed: Aug 7, 1991 | Docket: 466762

Cited 1 times | Published

from participation in the present action. Section 194.171, Fla. Stat. (1989). We hold the trial court

Mikos v. Parker

571 So. 2d 8, 1990 WL 66218

District Court of Appeal of Florida | Filed: May 18, 1990 | Docket: 1172982

Cited 1 times | Published

circuit court lacked jurisdiction, relying on section 194.171 which provides: (1) The circuit courts have

Schultz v. TM FLORIDA-OHIO REALTY LTD. P'SHIP

553 So. 2d 1203, 1989 WL 80705

District Court of Appeal of Florida | Filed: Dec 15, 1989 | Docket: 1675621

Cited 1 times | Published

arriving at a just valuation of property.[1] Section 194.171, Florida Statutes (1985), provides that a taxpayer

Winicki v. Mallard

615 F. Supp. 1244

District Court, M.D. Florida | Filed: Aug 16, 1985 | Docket: 66166143

Cited 1 times | Published

jurisdiction of the state court pursuant to Section 194.171, Fla. Stat., which provides a civil remedy

Cowart v. Perkins

445 So. 2d 654, 1984 Fla. App. LEXIS 11804

District Court of Appeal of Florida | Filed: Feb 15, 1984 | Docket: 64603022

Cited 1 times | Published

from the tax collector with the complaint. See § 194.-171(3), Fla.Stat. (Supp.1982).1 Appellant paid taxes

Manasota Burial Parks, Inc. v. Perkins

440 So. 2d 479, 1983 Fla. App. LEXIS 23529

District Court of Appeal of Florida | Filed: Nov 4, 1983 | Docket: 64600602

Cited 1 times | Published

December 1, 1981. Pursuant to the provisions of section 194.171, Florida Statutes (1981),1 appellants paid

Integrated Container Services, Inc. v. Overstreet

375 So. 2d 1146, 1979 Fla. App. LEXIS 15903

District Court of Appeal of Florida | Filed: Oct 16, 1979 | Docket: 1352525

Cited 1 times | Published

suit within the applicable non-claim period. F.S. 194.171(2). FAILURE TO OBTAIN AUTHORIZATION TO DO BUSINESS

Robert R. Turner v. Sharon W. Jordan

Court of Appeals for the Eleventh Circuit | Filed: Sep 17, 2024 | Docket: 68398166

Published

Argued: Apr 19, 2024

in the circuit courts. See Fla. Stat. § 194.171(1); Fla. Admin. Code Ann. r. 12D-13.066(1)

Shrewsbury v. Childers, Lunsford

District Court of Appeal of Florida | Filed: Jan 24, 2024 | Docket: 68187981

Published

tax assessments within the 60-day limit of section 194.171(2), Florida Statutes. That section provides

TAMPA PORT AUTHORITY v. BOB HENRIQUEZ, AS PROPERTY APPRAISER

District Court of Appeal of Florida | Filed: Dec 29, 2023 | Docket: 68123866

Published

rejection, Gulf Marine filed suit pursuant to section 194.171, advancing theories why the exemption's

Wayne Johansson v. Miami-Dade County Value Adjustment Board

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

Published

division’s decision also noted that, pursuant to section 194.171 of the Florida Statutes, the VAB was not a

SCOTT P. RUSSELL, etc. v. JAMES HASSETT

District Court of Appeal of Florida | Filed: Jun 28, 2023 | Docket: 67534533

Published

its plain and unambiguous language, though, section 194.171(2) imposes deadline limitations on an action

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

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

Published

Miami-Dade Property Appraiser. Pursuant to section 194.171, a taxpayer may contest a tax 2 A VAB decision

GARY W. JOINER, SUCCESSOR TO MIKE WELLS v. PINELLAS COUNTY, FLORIDA

District Court of Appeal of Florida | Filed: Sep 25, 2019 | Docket: 16243974

Published

analyzing whether the nonclaim provisions of section 194.171, Florida Statutes (2006), applied to State-owned

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

011(3); or file suit in circuit court under section 194.171, either first among these options or after

GARY W. JOINER, SUCCESSOR TO MIKE WELLS v. PINELLAS COUNTY, FLORIDA

District Court of Appeal of Florida | Filed: May 3, 2019 | Docket: 15048697

Published

analyzing whether the nonclaim provisions of section 194.171, Florida Statutes (2006), applied to State-owned

Edward A. Crapo, as Alachua County etc. and John Power, as Alachua County Tax Collector v. Gainesville Area Chamber of Commerce, Inc. etc.

274 So. 3d 453

District Court of Appeal of Florida | Filed: May 2, 2019 | Docket: 15042044

Published

before the VAB or directly in circuit court. § 194.171, Fla. Stat. A party that is unsuccessful before

Edward A. Crapo, as Alachua County etc. and John Power, as Alachua County Tax Collector v. Gainesville Area Chamber of Commerce, Inc. etc.

274 So. 3d 453

District Court of Appeal of Florida | Filed: May 2, 2019 | Docket: 15042044

Published

before the VAB or directly in circuit court. § 194.171, Fla. Stat. A party that is unsuccessful before

Dan Sowell, as Property Appraiser etc. v. Faith Christian Family Church Of Panama etc.

249 So. 3d 1323

District Court of Appeal of Florida | Filed: Jul 25, 2018 | Docket: 7510529

Published

challenge to the 2015 and 2016 years pursuant to section 194.171, Florida Statutes, because Faith Christian

STATE OF FLORIDA v. TASHANE M. CHANTILOUPE

248 So. 3d 1191

District Court of Appeal of Florida | Filed: Jun 6, 2018 | Docket: 7061984

Published

jurisdictional, it generally states as much. See, e.g., § 194.171(2), Fla. Stat. (2017). Here, in section 782.04(1)(b)

Garcia v. Dadeland Station Associates, Ltd.

218 So. 3d 474, 2017 Fla. App. LEXIS 6168

District Court of Appeal of Florida | Filed: May 3, 2017 | Docket: 6057955

Published

filed a suit to recover the payment under section 194.171, Florida Statutes (2015). 1 The

Garcia v. Dadeland Station Associates, Ltd.

District Court of Appeal of Florida | Filed: May 3, 2017 | Docket: 6060377

Published

filed a suit to recover the payment under section 194.171, Florida Statutes (2015).1 The County’s

City of Miami v. 346 Nw 29th Street, LLC

217 So. 3d 143, 2017 WL 1076899, 2017 Fla. App. LEXIS 3788

District Court of Appeal of Florida | Filed: Mar 22, 2017 | Docket: 4620363

Published

that the sixty-day non-claim provision of section 194.171(2) bars the action below and deprives the trial

City of Miami v. 346 Nw 29th Street, LLC

217 So. 3d 143, 2017 WL 1076899, 2017 Fla. App. LEXIS 3788

District Court of Appeal of Florida | Filed: Mar 22, 2017 | Docket: 4620363

Published

that the sixty-day non-claim provision of section 194.171(2) bars the action below and deprives the trial

American Heritage Window Fashions, LLC v. Department of Revenue

District Court of Appeal of Florida | Filed: May 6, 2016 | Docket: 3063090

Published

1988) (holding that analogous language in section 194.171, Florida Statutes, setting time limitations

City of Miami v. 346 NW 29th Street, LLC

184 So. 3d 592, 2016 Fla. App. LEXIS 1006, 2016 WL 313977

District Court of Appeal of Florida | Filed: Jan 27, 2016 | Docket: 60253333

Published

Miami’s acknowledgement that the application of section 194.171 of the Florida Statutes (the 60-day non-claim

City of Miami v. 346 Nw 29th Street, LLC

District Court of Appeal of Florida | Filed: Jan 27, 2016 | Docket: 3031225

Published

Miami’s acknowledgement that the application of section 194.171 of the Florida Statutes (the 60-day non-claim

Pam Dubov v. Sandra Ann Read

692 F.3d 1185, 2012 U.S. App. LEXIS 18466, 56 Bankr. Ct. Dec. (CRR) 258, 2012 WL 3738062

Court of Appeals for the Eleventh Circuit | Filed: Aug 30, 2012 | Docket: 2904061

Published

the Property Appraiser pursuant to Fla. Stat. § 194.171(2) (2009). 1 The Debtor filed an objection

De La Mora v. Andonie

51 So. 3d 517, 2010 Fla. App. LEXIS 19096, 2010 WL 5093142

District Court of Appeal of Florida | Filed: Dec 15, 2010 | Docket: 2396292

Published

filed in the Eleventh Judicial Circuit Court. See § 194.171(1), Fla. Stat. (2006).[2] On cross-motions for

Aulet v. Castro

44 So. 3d 140, 2010 Fla. App. LEXIS 10862, 2010 WL 2925386

District Court of Appeal of Florida | Filed: Jul 28, 2010 | Docket: 60295566

Published

jurisdictional.” Further, subsection (2) of section 194.171 sets forth a sixty-day limit for challenging

Shank v. Havill

6 So. 3d 631, 2009 Fla. App. LEXIS 3454, 2009 WL 413361

District Court of Appeal of Florida | Filed: Feb 20, 2009 | Docket: 60299790

Published

with the conditions precedent set forth in section 194.171, Florida Statutes (2007). We reverse. The Shanks

Belden v. TWA LTD. PARTNERSHIP

982 So. 2d 721

District Court of Appeal of Florida | Filed: Apr 18, 2008 | Docket: 1664313

Published

which TWA admitted in good faith to be owing. See § 194.171(3), Fla. Stat. (2002-2005). The full amount of

Black v. Jacobs

974 So. 2d 1172, 2008 Fla. App. LEXIS 2302, 2008 WL 440988

District Court of Appeal of Florida | Filed: Feb 20, 2008 | Docket: 64853936

Published

PER CURIAM. Affirmed. See § 194.171(2), (6), Fla. Stat. (2005).

Crapo v. HCA, INC.

968 So. 2d 54, 2007 WL 2932868

District Court of Appeal of Florida | Filed: Oct 10, 2007 | Docket: 1498216

Published

nonhomestead property for taxation purposes. See § 194.171(1), Fla. Stat. (2006) (providing that the circuit

Alvarez v. Whispering Oaks Housing Partners, II, Ltd.

963 So. 2d 341, 2007 Fla. App. LEXIS 12944, 2007 WL 2362362

District Court of Appeal of Florida | Filed: Aug 21, 2007 | Docket: 64851909

Published

complaint as untimely under the provisions of section 194.171(2), Florida Statutes. The motion was denied

State, Department of Management Services v. Cason

909 So. 2d 378, 2005 Fla. App. LEXIS 12185

District Court of Appeal of Florida | Filed: Aug 4, 2005 | Docket: 64840122

Published

certification for collection, as required by section 194.171(2), Florida Statutes (2000). Because we conclude

Florida Furniture Industries, Inc. v. Mahaffey (In Re Florida Furniture Industries, Inc.)

342 B.R. 838, 18 Fla. L. Weekly Fed. B 169, 53 Collier Bankr. Cas. 2d 1221, 2005 Bankr. LEXIS 150, 2005 WL 419701

United States Bankruptcy Court, M.D. Florida | Filed: Feb 9, 2005 | Docket: 1101990

Published

challenging an excessive assessment pursuant to Section 194.171(2), (3) and (6), Florida Statutes (2003). 5

Suber v. Pultz

889 So. 2d 947, 2004 WL 2924206

District Court of Appeal of Florida | Filed: Dec 17, 2004 | Docket: 1488697

Published

failed to comply with the requirements of section 194.171, Florida Statutes, a jurisdictional statute

Todora v. Silverstein

889 So. 2d 177, 2004 Fla. App. LEXIS 19097, 2004 WL 2895610

District Court of Appeal of Florida | Filed: Dec 15, 2004 | Docket: 64834999

Published

filed within the sixty-day window provided by section 194.171(2), Florida Statutes (1997-2002). The trial

Lee v. Hartsfield

848 So. 2d 430, 2003 Fla. App. LEXIS 9900, 2003 WL 21502783

District Court of Appeal of Florida | Filed: Jul 2, 2003 | Docket: 64823779

Published

which the trial court ruled that, pursuant to section 194.171(2), Florida Statutes (1999), it lacked subject

Department of Revenue v. Pepperidge Farm, Inc.

847 So. 2d 575, 2003 WL 21394197

District Court of Appeal of Florida | Filed: Jun 18, 2003 | Docket: 64823367

Published

deprived the trial court of jurisdiction. See § 194.171(6). Pepperidge Farm responded that it was not

Todora v. Venice Golf & Country Club 1, Inc.

826 So. 2d 406, 2002 Fla. App. LEXIS 10684, 2002 WL 1723915

District Court of Appeal of Florida | Filed: Jul 26, 2002 | Docket: 64817625

Published

and 2000, Venice Golf filed suit pursuant to section 194.171, Florida Statutes (1999). Venice Golf is a

Turner v. Concorde Properties

823 So. 2d 165, 2002 Fla. App. LEXIS 9166, 2002 WL 1394723

District Court of Appeal of Florida | Filed: Jun 28, 2002 | Docket: 64816765

Published

Concorde filed suit in circuit court pursuant to section 194.171, Florida Statutes (1997). Both Turner and Concorde

Barrett Tool Rental, Inc. v. Metropolitan Miami Dade

802 So. 2d 1166, 2001 Fla. App. LEXIS 17081, 2001 WL 1538957

District Court of Appeal of Florida | Filed: Dec 5, 2001 | Docket: 64811241

Published

that it lacked subject matter jurisdiction.1 See § 194.171(2), Florida Statutes (1999); Markham v. Neptune

Palm Beach Gardens Community Hospital, Inc. v. Nikolits

754 So. 2d 729, 1999 Fla. App. LEXIS 14587, 1999 WL 993145

District Court of Appeal of Florida | Filed: Nov 3, 1999 | Docket: 64796290

Published

lack of subject matter jurisdiction under section 194.171, Florida Statutes (1997). *730Appellees thereafter

Moore v. Palm Beach County

731 So. 2d 754, 1999 WL 187098

District Court of Appeal of Florida | Filed: Apr 7, 1999 | Docket: 1409115

Published

failed to timely contest taxes pursuant to section 194.171(2), Florida Statutes. That section requires

Palm Bay Towers Condominium Ass'n v. Robbins

705 So. 2d 715, 1998 Fla. App. LEXIS 1345, 1998 WL 65335

District Court of Appeal of Florida | Filed: Feb 18, 1998 | Docket: 64778765

Published

PER CURIAM. Affirmed. § 194.171(2), (6), Fla. Stat. (1995).

Palmer Trinity Private School, Inc. v. Robbins

681 So. 2d 809, 1996 Fla. App. LEXIS 10409, 1996 WL 577151

District Court of Appeal of Florida | Filed: Oct 9, 1996 | Docket: 64768431

Published

court held that pursuant to Florida Statute section 194.171(2) (1993), it did not have jurisdiction over

City of Fernandina Beach v. Page

682 So. 2d 573, 1996 Fla. App. LEXIS 10380, 1996 WL 571174

District Court of Appeal of Florida | Filed: Oct 8, 1996 | Docket: 64768723

Published

rendering of the Board’s decision, as required by section 194.171(2), Florida Statutes (1995). The City argues

Ago

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

Published

Section 193.122(1), Fla. Stat. (1995). 10 Section 194.171(2), Fla. Stat. (1995). 11 See, Op. Att'y Gen

Ago

Florida Attorney General Reports | Filed: Feb 23, 1995 | Docket: 3257600

Published

certification is before the value adjustment board. Section 194.171(2), Florida Statutes (1994 Supp.), provides:

Horizons Condominium Management Ass'n v. Salvato

641 So. 2d 922, 1994 Fla. App. LEXIS 7508, 1994 WL 390783

District Court of Appeal of Florida | Filed: Jul 29, 1994 | Docket: 64750513

Published

challenge the assessor’s past assessments. See § 194.171(2), Fla.Stat. Because assessments on the yard

Santana v. Metropolitan Dade County

641 So. 2d 117, 1994 Fla. App. LEXIS 5214, 1994 WL 234519

District Court of Appeal of Florida | Filed: May 31, 1994 | Docket: 64750293

Published

alternatively for affirmance under authority of section 194.-171(3) — (6), Florida Statutes (1993). However

Section 3 Property Corp. v. Robbins

632 So. 2d 596, 19 Fla. L. Weekly Supp. 1, 1993 Fla. LEXIS 1997, 1993 WL 528461

Supreme Court of Florida | Filed: Dec 23, 1993 | Docket: 64746552

Published

statute makes no specific reference to equity. § 194.171, Fla.Stat. (1991). Even so, had there ever been

Dept. of Revenue v. NU-LIFE HEALTH

623 So. 2d 747

District Court of Appeal of Florida | Filed: Aug 30, 1993 | Docket: 1658186

Published

moved to dismiss pursuant to the provision in section 194.171(5), Florida Statutes (1985), that a taxpayer

Walker v. Palm Beach Commerce Center Associated, Ltd.

614 So. 2d 1097, 18 Fla. L. Weekly Supp. 141, 1993 Fla. LEXIS 329, 1993 WL 64632

Supreme Court of Florida | Filed: Mar 11, 1993 | Docket: 64694706

Published

Associates, Ltd., filed a complaint pursuant to section 194.171, Florida Statutes (1989), contesting the 1990

Printing House, Inc. v. State, Department of Revenue

614 So. 2d 1119, 1992 Fla. App. LEXIS 13597, 1992 WL 389020

District Court of Appeal of Florida | Filed: Dec 31, 1992 | Docket: 64694718

Published

agricultural exemption. Robbins construed section 194.171, Florida Statutes (1991), as providing a remedy

Southards v. Motel Management Co.

610 So. 2d 524, 1992 Fla. App. LEXIS 12063, 1992 WL 353411

District Court of Appeal of Florida | Filed: Dec 1, 1992 | Docket: 64692807

Published

defendant Knight was clearly authorized by Section 194.171(3), Florida Statutes (1991), as a precondition

Zorrilla v. Robbins

606 So. 2d 699, 1992 Fla. App. LEXIS 10466, 1992 WL 261150

District Court of Appeal of Florida | Filed: Oct 6, 1992 | Docket: 64670851

Published

PER CURIAM. Affirmed. Section 194.171(3), (6), Fla. Stat. (1991). See Millstream Corp. v. Dade County

Palm Beach Commerce Center Associated, Ltd. v. Walker

598 So. 2d 165, 1992 Fla. App. LEXIS 4730, 1992 WL 83903

District Court of Appeal of Florida | Filed: Apr 29, 1992 | Docket: 64667106

Published

FACTS Appellant filed a complaint pursuant to section 194.171, Florida Statutes (1991), alleging that the

International Society for Krishna Consciousness of Miami Beach, Inc. v. Robbins

583 So. 2d 767, 1991 Fla. App. LEXIS 7590, 1991 WL 147701

District Court of Appeal of Florida | Filed: Aug 6, 1991 | Docket: 64660650

Published

to meet the jurisdictional requirement in section 194.171(3), Florida Statutes (1989): Before an action

Pier House Joint Venture v. Higgs

579 So. 2d 392, 1991 Fla. App. LEXIS 4647, 1991 WL 82521

District Court of Appeal of Florida | Filed: May 21, 1991 | Docket: 64658678

Published

its complaint within sixty days pursuant to section 194.-171(2), Florida Statutes (1989). Since the Florida

Ago

Florida Attorney General Reports | Filed: May 13, 1991 | Docket: 3256337

Published

assessment within the time frame set forth in section 194.171, Florida Statutes, or to order a refund resulting

Zorrilla v. Robbins

568 So. 2d 482, 1990 Fla. App. LEXIS 7708, 1990 WL 149812

District Court of Appeal of Florida | Filed: Oct 9, 1990 | Docket: 64653811

Published

See Bystrom v. Diaz, 514 So.2d 1072 (Fla.1987); § 194.171(6), Fla. Stat. (1989).

Southards v. Motel Management Co.

567 So. 2d 523, 1990 Fla. App. LEXIS 7287, 1990 WL 138422

District Court of Appeal of Florida | Filed: Sep 25, 1990 | Docket: 64653383

Published

deposited in escrow the amount required by section 194.171, Florida Statutes. Included in that deposit

Wilkinson v. St. Jude Harbors, Inc.

570 So. 2d 1332, 1990 Fla. App. LEXIS 5042, 1990 WL 96241

District Court of Appeal of Florida | Filed: Jul 11, 1990 | Docket: 64654899

Published

argument, the taxpayer’s failure to comply with section 194.171(3) by paying “the amount of the tax which he

Bell v. Bryan

519 So. 2d 1024, 13 Fla. L. Weekly 131, 1988 Fla. App. LEXIS 34, 1988 WL 790

District Court of Appeal of Florida | Filed: Jan 5, 1988 | Docket: 64632615

Published

1060 (Fla.1987). As to Issue II, we note that section 194.171(2), Florida Statutes (1983),1 applies on its

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

his own more definite statement. Pursuant to section 194.171(2), Florida Statutes (1975), petitioning property

Turnberry Towers Corp. v. Bystrom

496 So. 2d 198, 1986 Fla. App. LEXIS 10260

District Court of Appeal of Florida | Filed: Oct 28, 1986 | Docket: 64622362

Published

1985), rev. denied, 488 So.2d 830 (Fla.1986); § 194.171(2), (6), Fla.Stat. (1983).

Valencia Center, Inc. v. Bystrom

496 So. 2d 198, 1986 Fla. App. LEXIS 10064

District Court of Appeal of Florida | Filed: Oct 14, 1986 | Docket: 64622361

Published

1985), review denied, 488 So.2d 830 (Fla.1986); § 194.171(2), (6), Fla.Stat. (1983); cf. Miller v. Nolte

Crews Lake Road & Bridge District v. Pineview Estates, Inc. (In re Pineview Estates, Inc.)

57 B.R. 483, 1986 Bankr. LEXIS 6985

United States Bankruptcy Court, M.D. Florida | Filed: Jan 2, 1986 | Docket: 65779104

Published

challenge taxes in this State is dealt with by § 194.171 of the Fla.Stat. This Statute provides, inter

Markham v. Corlett

453 So. 2d 907, 9 Fla. L. Weekly 1728, 1984 Fla. App. LEXIS 14612

District Court of Appeal of Florida | Filed: Aug 8, 1984 | Docket: 64606235

Published

assessment is barred by the provisions of Section 194.-171(3), (5) and (6), Florida Statutes (1983).

Autotote Ltd. v. Bystrom

454 So. 2d 661, 1984 Fla. App. LEXIS 14392

District Court of Appeal of Florida | Filed: Jul 24, 1984 | Docket: 64606448

Published

Inc. v. Gerstung, 262 So.2d 1, 4 (Fla.1972); § 194.171(1), Fla.Stat. (1983), we conclude that the trial

Redford v. State, Department of Revenue

452 So. 2d 961, 1984 Fla. App. LEXIS 13592

District Court of Appeal of Florida | Filed: Jun 12, 1984 | Docket: 64605876

Published

all defenses in a subsequent proceeding. See § 194.171(2), Fla.Stat. (1977). This is particularly true

Aquarius Condominium Ass'n v. Markham

442 So. 2d 423, 1983 Fla. App. LEXIS 25264

District Court of Appeal of Florida | Filed: Dec 21, 1983 | Docket: 64601556

Published

under protest “or to follow the provisions of Section 194.171(3), F.S. and tender to the Revenue Collector

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

“that the 60-day time limitation expressed in Section 194.-171(2) ... is a jurisdictional statute of non-claim

Wilson v. School Board of Marion County

424 So. 2d 16, 8 Educ. L. Rep. 887, 1982 Fla. App. LEXIS 21254

District Court of Appeal of Florida | Filed: Sep 29, 1982 | Docket: 64594346

Published

They filed a class action suit1 pursuant to section 194.171, Florida Statutes (1981), challenging the validity

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

subject only to the limitations imposed under section 194.-171, Florida Statutes (1979). The facts pertaining

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

upon a $37,000,000 valuation as required by Section 194.171(4), supra.12 The trial court determined the

Smith v. University Presbyterian Homes, Inc.

390 So. 2d 79, 1980 Fla. App. LEXIS 17396

District Court of Appeal of Florida | Filed: Oct 15, 1980 | Docket: 64578777

Published

much of its force when examined in light of Section 194.171(3), Florida Statutes (1979), which permits

Reid v. Lucom

349 So. 2d 661, 1977 Fla. App. LEXIS 16036

District Court of Appeal of Florida | Filed: Aug 2, 1977 | Docket: 64560014

Published

obvious that the Plaintiff failed to comply with Section 194.171(3) and (4), Florida Statutes (1975) in that

Coe v. ITT Community Development Corp.

349 So. 2d 654, 1977 Fla. App. LEXIS 16535

District Court of Appeal of Florida | Filed: Jul 29, 1977 | Docket: 64560012

Published

the assessment was certified for collection. Section 194.171, Florida Statutes (1975) provides in part:

City National Bank of Miami v. Blake

257 So. 2d 264, 1972 Fla. App. LEXIS 7533

District Court of Appeal of Florida | Filed: Feb 1, 1972 | Docket: 64524182

Published

circuit court. They further contend that under § 194.171, Fla.Stat., F.S.A. the arbitration was not conclusive