Florida Statute 194.181 - 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. 194.181

194.181 Parties to a tax suit.—

(1) The plaintiff in any tax suit shall be:

(a) The taxpayer or other person contesting the assessment of any tax, the payment of which he or she is responsible for under a statute or a person who is responsible for the entire tax payment pursuant to a contract and has the written consent of the property owner, or the condominium association, cooperative association, or homeowners’ association as defined in s. 723.075 which operates the units subject to the assessment; or

(b) The property appraiser pursuant to s. 194.036.

(2)(a) In any case brought by a taxpayer or a condominium or cooperative association, as defined in ss. 718.103 and 719.103, respectively, on behalf of some or all unit or parcel owners, contesting the assessment of any property, the county property appraiser is a party defendant.

(b) Other than as provided in paragraph (c), in any case brought by the property appraiser under s. 194.036(1)(a) or (b), the taxpayer is a party defendant.

(c)1. In any case brought by the property appraiser under s. 194.036(1)(a) or (b) relating to a value adjustment board decision on a single joint petition filed by a condominium or cooperative association under s. 194.011(3), the association is the only required party defendant. The individual unit or parcel owners are not required to be named as parties.

2. The condominium or cooperative association must provide unit or parcel owners with notice of the property appraiser’s complaint and advise the unit or parcel owners that they may elect to:

a. Retain their own counsel to defend the appeal for their units or parcels;

b. Choose not to defend the appeal; or

c. Be represented by the association.

3. The notice required in subparagraph 2. must be hand delivered or sent by certified mail, return receipt requested, except that such notice may be electronically transmitted to a unit or parcel owner who has expressly consented in writing to receiving such notices through electronic transmission. Additionally, the notice must be posted conspicuously on the condominium or cooperative property, if applicable, in the same manner as notices of board meetings under ss. 718.112(2) and 719.106(1). The association must provide at least 14 days for a unit or parcel owner to respond to the notice. Any unit or parcel owner who does not respond to the association’s notice will be represented by the association.

4. If requested by a unit or parcel owner, the tax collector shall accept payment of the estimated amount in controversy, as determined by the tax collector, as to that unit or parcel, whereupon the unit or parcel shall be released from any lis pendens and the unit or parcel owner may elect to remain in or be dismissed from the action.

(d) In any case brought by the property appraiser under s. 194.036(1)(c), the value adjustment board is a party defendant.

(3) In any suit involving the collection of any tax on property, as well as questions relating to tax certificates or applications for tax deeds, the tax collector charged under the law with collecting such tax shall be the defendant.

(4) In any suit involving a tax other than an ad valorem tax on property, the tax collector charged under the law with collecting such tax shall be defendant. However, this section does not apply in any instance wherein general law provides for some other person to be the party defendant.

(5) In any suit in which the assessment of any tax, or the collection of any tax, tax certificate, or tax deed is contested on the ground that it is contrary to the State Constitution, the official of the state government responsible for overall supervision of the assessment and collection of such tax shall be made a party defendant of such suit. Any such suit shall be brought in that county having venue under s. 194.171 or, when that section is inapplicable, in the Circuit Court of Leon County, and the attorney for the defendant county officer shall upon request represent the state official in any such suit or proceeding, for which he or she shall receive no additional compensation.

(6) In any suit in which the validity of any statute or regulation found in, or issued pursuant to, chapters 192-197, inclusive, is contested, the public officer affected may be a party plaintiff.

History.—s. 3, ch. 8586, 1921; CGL 1040; ss. 1, 2, ch. 69-55; s. 7, ch. 69-140; s. 32, ch. 70-243; s. 1, ch. 73-74; s. 9, ch. 76-133; s. 4, ch. 76-234; s. 1, ch. 77-174; s. 27, ch. 83-204; s. 4, ch. 88-146; s. 152, ch. 91-112; s. 983, ch. 95-147; s. 7, ch. 2004-349; s. 2, ch. 2021-209.

Note.—Former s. 196.03.

F.S. 194.181 on Google Scholar

F.S. 194.181 on CourtListener

Amendments to 194.181

Annotations, Discussions, Cases:

Cases Citing Statute 194.181

Total Results: 39

Zingale v. Powell

885 So. 2d 277, 2004 WL 2050106

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

Cited 43 times | Published

requirements for parties in a tax suit under section 194.181, Florida Statutes (2001), the Powells named

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

(emphasis added).[7] The 1976 act likewise revised section 194.181(1) to include an appraiser *802 appealing from

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

was joined as a party defendant pursuant to Section 194.181(5), Florida Statutes (1979), and later moved

Williams v. Law

368 So. 2d 1285

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

Cited 10 times | Published

civil action rather than by appeal. Further, section 194.181, Florida Statutes (Supp. 1976), provides in

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

after the jurisdictional time period expired. Section 194.181, Florida Statutes (1993) requires that in any

Southern Bell Tel. & Tel. Co. v. Broward

665 So. 2d 272, 1995 WL 540272

District Court of Appeal of Florida | Filed: Nov 22, 1995 | Docket: 1351919

Cited 8 times | Published

was joined as a party defendant pursuant to Section 194.181(5), Florida Statutes. However, Southern Bell

Turner v. HILLSBOROUGH AVIATION AUTH.

739 So. 2d 175, 1999 WL 682598

District Court of Appeal of Florida | Filed: Sep 3, 1999 | Docket: 1688791

Cited 6 times | Published

DOR was an indispensable party pursuant to section 194.181(5), Florida Statutes (1997), which provides

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

also named as a defendant in the action. See § 194.181(5), Fla. Stat. (1991). In its complaint, CPA alleged

Garcia v. Andonie

101 So. 3d 339, 37 Fla. L. Weekly Supp. 613, 2012 WL 4666458, 2012 Fla. LEXIS 1923

Supreme Court of Florida | Filed: Oct 4, 2012 | Docket: 60226264

Cited 5 times | Published

to the circuit court action as permitted by section 194.181(5), Fla. Stat. (2007). In the circuit court

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

(Section 194.171, Florida Statutes (1981)). Section 194.181, Florida Statutes (1981), provides that (1)

Muckenfuss v. Miller

421 So. 2d 170

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

Cited 5 times | Published

necessary defendants in Deltona's suit pursuant to section 194.181, Florida Statutes (1981). [2] See Straughn

Spooner v. Askew

345 So. 2d 1055

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

Cited 5 times | Published

detailed investigations. [4] As required by Section 194.181(2), Florida Statutes (1973), the Board and

In Re Polygraphex Systems, Inc.

275 B.R. 408, 48 Collier Bankr. Cas. 2d 96, 15 Fla. L. Weekly Fed. B 123, 2002 Bankr. LEXIS 241, 39 Bankr. Ct. Dec. (CRR) 68

United States Bankruptcy Court, M.D. Florida | Filed: Mar 25, 2002 | Docket: 1475958

Cited 4 times | Published

Appraiser is made a party to the Objection is section 194.181(2) of the Florida Statutes, which states that

Fuchs v. Robbins

738 So. 2d 338, 1998 WL 821744

District Court of Appeal of Florida | Filed: Jul 16, 1999 | Docket: 414838

Cited 4 times | Published

January 1 of each year as the taxing date. [25] Section 194.181 provides as follows: "(1) The plaintiff in

Southern Bell Tel. & Tel. v. Markham

632 So. 2d 272, 1994 WL 51869

District Court of Appeal of Florida | Filed: Feb 23, 1994 | Docket: 176720

Cited 4 times | Published

was joined as a party defendant pursuant to Section 194.181(5), Florida Statutes. We affirm the judgment

Department of Revenue v. Markham

381 So. 2d 1101

District Court of Appeal of Florida | Filed: Nov 5, 1979 | Docket: 1722559

Cited 3 times | Published

household goods and personal effects." [4] Section 194.181(6), Florida Statutes 1977, provides: "In any

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

amount which he or she admits to owing. In section 194.181(1)(a),[2] the taxpayer is in part identified

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

Appraiser is an indispensable party pursuant to § 194.181(2), Florida Statutes because the Adversary Proceeding

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

Florida Statutes (1985), and specifically section 194.181, entitled "Parties to a Tax Suit," calls for

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

challenge the 2012 assessment, See § 194.181(1)(a), Fla. Stat, (2012), Neff is seeking to raise

Sowell v. State

136 So. 3d 1285, 2014 Fla. App. LEXIS 7050, 2014 WL 1882209

District Court of Appeal of Florida | Filed: May 12, 2014 | Docket: 60239971

Cited 1 times | Published

directly against the VAB for injunctive relief. See § 194.181(2) (providing that in any other case brought by

Yorty v. Abreu

988 So. 2d 1155, 2008 Fla. App. LEXIS 11840, 2008 WL 2986425

District Court of Appeal of Florida | Filed: Aug 6, 2008 | Docket: 64855552

Cited 1 times | Published

proceedings consistent with this opinion. . Section 194.181(3), Florida Statutes (2003), states: "In any

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

proceed. VGA prevailed after a two-day trial. Section 194.181, Florida Statutes (1999) and (2000), designates

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

to be the governing *611 statute; namely, section 194.181, Florida Statutes. At oral argument counsel

Pedro J. Garcia, Etc. v. Piper Industrial Complex, LLC

District Court of Appeal of Florida | Filed: Aug 13, 2025 | Docket: 71098942

Published

as an indispensable party as required by section 194.181(3), Florida Statutes (2023) (requiring the

TAMPA PORT AUTHORITY v. BOB HENRIQUEZ, AS PROPERTY APPRAISER

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

Published

defendant, whereas a third statute involved here, section 194.181(2), requires that "[i]n any case brought

SCOTT P. RUSSELL, etc. v. JAMES HASSETT

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

Published

issues raised in the complaint. 5 5 See § 194.181(5), Fla. Stat. (2017).

SCOTT P. RUSSELL, etc. v. JAMES HASSETT

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

Published

issues raised in the complaint. 5 5 See § 194.181(5), Fla. Stat. (2017).

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

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

Published

2 The VAB argued that section 194.181, Florida Statutes, provides that the proper

Central Carillon Beach Condo. Assoc., Inc. v. Garcia

245 So. 3d 869

District Court of Appeal of Florida | Filed: Mar 21, 2018 | Docket: 6340884

Published

determination of the county’s value adjustment board, section 194.181(2), Florida Statutes (2016), apparently presents

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

amount which he or she admits to owing. In section 194.181(l)(a),2 the taxpayer is in part identified

In Re Court Divisions

648 So. 2d 761

District Court of Appeal of Florida | Filed: Oct 3, 1994 | Docket: 1701987

Published

all parts of an assessment roll) *762 (j) Section 194.181(5) (Constitutional challenges to tax assessments)

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

collector was not included as a defendant. Compare section 194.181(3), Florida Statutes (1987) (providing for

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

general principles which govern standing. Fla.Stat. § 194.181 (1983) specifically sets forth who may contest

Schultz v. Williams

472 So. 2d 1347, 10 Fla. L. Weekly 1815, 1985 Fla. App. LEXIS 14426

District Court of Appeal of Florida | Filed: Jul 24, 1985 | Docket: 64613275

Published

responsible for defending the county's tax roll. § 194.181, Fla.Stat. Here, after assessing the plaintiffs’

Florida Department of Revenue v. Ford

417 So. 2d 1109, 74 Oil & Gas Rep. 195, 1982 Fla. App. LEXIS 20834

District Court of Appeal of Florida | Filed: Aug 11, 1982 | Docket: 64591645

Published

compliance with the mandatory requirements of section 194.181(5), Florida Statutes (1982). The taxpayers’

City of North Miami Beach v. Eastern Shores Sales Co.

341 So. 2d 825, 1977 Fla. App. LEXIS 15153

District Court of Appeal of Florida | Filed: Jan 25, 1977 | Docket: 64556763

Published

assessment *827already made on his property. Section 194.-181(2), Florida Statutes (1971)1 provides: “In

Ago

Florida Attorney General Reports | Filed: Jun 19, 1975 | Docket: 3256125

Published

the validity or invalidity of the statute. Section 194.181(6), F.S., states: In any suit in which the

Escom Enterprises, Inc. v. Markham

311 So. 2d 402

District Court of Appeal of Florida | Filed: Apr 18, 1975 | Docket: 64545866

Published

indispensable parties to this action (see Section 194.181(5), Florida Statutes 1973) and that counts