Florida Statutes

Fla. Stat. § 194.192 (2025)

Costs; interest on unpaid taxes; penalty.

✓ 2025 Florida Statutes — current through the 2025 Regular Session Cite as: Fla. Stat. § 194.192 (2025)

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194.192 Costs; interest on unpaid taxes; penalty.—

(1) In any suit involving the assessment or collection of any tax, the court shall assess all costs.

(2) If the court finds that the amount of tax owed by the taxpayer is greater than the amount the taxpayer has in good faith admitted and paid, it shall enter judgment against the taxpayer for the deficiency and for interest on the deficiency at the rate of 12 percent per year from the date the tax became delinquent. If it finds that the amount of tax which the taxpayer has admitted to be owing is grossly disproportionate to the amount of tax found to be due and that the taxpayer’s admission was not made in good faith, the court shall also assess a penalty at the rate of 10 percent of the deficiency per year from the date the tax became delinquent.

History.—s. 8, ch. 69-140; s. 33, ch. 70-243; s. 35, ch. 71-355; s. 2, ch. 72-239; s. 18, ch. 82-226; s. 4, ch. 96-397.

Notes of Decisions

Cited in 12 cases (1 in the last 5 years), 1971–2023 · leading case: Muckenfuss v. Miller

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Muckenfuss v. Miller (1982) fladistctapp · cites it 6× “Because these calculations will change the amounts of the final judgments, we remand these proceedings for amendment of the judgments.”

North Port Bank v. State, Department of Revenue (1975) fla · cites it 4× “171 (4) and Section 194.192(2), Florida Statutes, relating to real property, which read as follows: "Section 194.”

Malibu Partners, Ltd. v. Schooley (1979) fladistctapp · cites it 2× “Section 194.192(2). Assuming, but not deciding, that appellees' interpretation of Section 194.”

Hotelerama Associates, Ltd. v. Bystrom (1984) fladistctapp · cites it 2× “…is actually owed does not preclude granting injunctive relief, but is the basis for stiff statutory penalties. See § 194.192, Fla. Stat. (1983).”

Bystrom v. Equitable Life Assurance Society of United States (1982) fladistctapp · cites it 2× “Section 194.192(2), Florida Statutes (1977), expressly provides: (2) If the court finds that the amount of tax owed by the taxpayer is greater than the amount the taxpayer has in good faith admitted and paid, it shall enter judgment against the taxpayer for the deficiency and…”

Champion Realty Corp. v. Burgess (1989) fladistctapp · cites it 2× “The tax collector subsequently requested the court to enter a money judgment against Champion Realty pursuant to the provisions of section 194.192, Florida Statutes. The second judgment appealed was thereafter rendered granting the money judgment.”

Palm Beach Commerce Center Associated, Ltd. v. Walker (1992) fladistctapp · cites it 7× “See § 194.192, Fla.Stat. (1983). Id. 449 So.2d at 838 n.”

Bystrom v. EQUITABLE LIFE ASSUR. SOC., ETC. (1982) fladistctapp · cites it 2× “Section 194.192(2), Florida Statutes (1977), expressly provides: (2) If the court finds that the amount of tax owed by the taxpayer is greater than the amount the taxpayer has in good faith admitted and paid, it shall enter judgment against the taxpayer for the deficiency and…”

RAMLE INTERNATIONAL CORP. v. MIAMI-DADE COUNTY, FLORIDA (2023) fladistctapp · cites it 2× “2 In counts one and six, 2 On appeal, Ramle also asserts the trial court erred in awarding costs to the County and DOR under section 194.192, Florida Statutes. In their briefs, however, both the County and DOR waived entitlement to recover costs in this action.”

Adler v. Tax Assessor (1971) flacirct17bro · cites it 6× “1969 Fla. Stat. §194.192 (2). The difference in taxes so computed shall then be reduced to the amount plaintiffs would have paid by taking the November discount.”

Belden v. TWA LTD. PARTNERSHIP (2008) fladistctapp “NOTES [1] TWA concedes that although taxpayers are required to pay interest on tax underpayments, see § 194.192(2), taxpayers who make overpayments are not entitled to recover interest.”

Hotelerama Associates, Ltd. v. Bystrom (1987) flacirct “See § 194.192(2), Florida Statutes (1983). Accordingly, it is ORDERED AND ADJUDGED that: 1.”

— 194.192(2) — 8 cases

Muckenfuss v. Miller (1982) fladistctapp “Because these calculations will change the amounts of the final judgments, we remand these proceedings for amendment of the judgments.”

North Port Bank v. State, Department of Revenue (1975) fla “171 (4) and Section 194.192(2), Florida Statutes, relating to real property, which read as follows: "Section 194.”

Malibu Partners, Ltd. v. Schooley (1979) fladistctapp “Section 194.192(2). Assuming, but not deciding, that appellees' interpretation of Section 194.”

Bystrom v. Equitable Life Assurance Society of United States (1982) fladistctapp “Section 194.192(2), Florida Statutes (1977), expressly provides: (2) If the court finds that the amount of tax owed by the taxpayer is greater than the amount the taxpayer has in good faith admitted and paid, it shall enter judgment against the taxpayer for the deficiency and…”

Bystrom v. EQUITABLE LIFE ASSUR. SOC., ETC. (1982) fladistctapp “Section 194.192(2), Florida Statutes (1977), expressly provides: (2) If the court finds that the amount of tax owed by the taxpayer is greater than the amount the taxpayer has in good faith admitted and paid, it shall enter judgment against the taxpayer for the deficiency and…”

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