Kentucky Revised Statutes

Ky. Rev. Stat. § 134.590 (2026)

Refund of ad valorem taxes or taxes held unconstitutional

✓ current as of May 2026
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(1) When the appropriate state government agency determines that a taxpayer has paid ad valorem taxes into the state treasury when no taxes were due or has paid under a statute held unconstitutional, the state government agency which administers the tax shall refund the money, or cause it to be refunded, to the person who paid the tax. The state government agency shall not authorize a refund to a person who has paid the tax due on any tract of land unless the taxpayer has paid the entire tax due the state on the land. (2) No state government agency shall authorize a refund unless each taxpayer individually applies for a refund within two (2) years from the date the taxpayer paid the tax. Each claim or application for a refund shall be in writing and state the specific grounds upon which it is based. Denials of refund claims or applications may be protested and appealed in accordance with KRS 49.220 and 131.110. No state government agency shall refund ad valorem taxes, except those held unconstitutional, unless the taxpayer has properly followed the administrative remedy procedures established through the protest provisions of KRS 131.110, the appeal provisions of KRS 133.120, the correction provisions of KRS 133.110 and 133.130, or other administrative remedy procedures. (3) If a taxpayer pays city, urban-county, county, school district, consolidated local government, or special district ad valorem taxes to a city, urban-county, county, school district, consolidated local government, or special district when no taxes were due or the amount paid exceeded the amount finally determined to be due, the taxes shall be refunded to the person who paid the tax. (4) Refunds of ad valorem taxes shall be authorized by the mayor or chief finance officer of any city, consolidated local government, or urban-county government for the city, consolidated local government, or urban-county government or for any special district for which the city, consolidated local government, or urban-county government is the levying authority, by the county judge/executive of any county for the county or special district for which the fiscal court is the levying authority, or by the chairman or finance officer of any district board of education. (5) Upon proper authorization, the sheriff or collector shall refund the taxes from current tax collections he or she holds. If there are no such funds, the district's finance officer shall make the refunds. The sheriff or collector shall receive credit on the next collection report to the district for any refunds the sheriff or collector makes. (6) No refund shall be made unless each taxpayer individually applies within two (2) years from the date payment was made. If the amount of taxes due is in litigation, the taxpayer shall individually apply for refund within two (2) years from the date the amount due is finally determined. Each claim or application for a refund shall be in writing and state the specific grounds upon which it is based. No refund for ad valorem taxes, except those held unconstitutional, shall be made unless the taxpayer has properly followed the administrative remedy procedures established through the protest provisions of KRS 131.110, the appeal provisions of KRS 133.120, the correction provisions of KRS 133.110 and 133.130, or other administrative remedy procedures. (7) Notwithstanding other statutory provisions, for property subject to a tax rate that is set each year based on the certified assessment, a taxing district may recover any loss of ad valorem tax revenue it suffers due to the issuance of refunds by adjusting the following tax year's tax rate. Effective:June 29, 2017 History: Amended 2017 Ky. Acts ch. 74, sec. 77, effective June 29, 2017. -- Amended 2005 Ky. Acts ch. 112, sec. 2, effective June 20, 2005. -- Amended 2002 Ky. Acts ch. 346, sec. 172, effective July 15, 2002. -- Amended 1996 Ky. Acts ch. 344, sec. 2, effective July 15, 1996. -- Amended 1992 Ky. Acts ch. 391, sec. 5, effective July 14, 1992. -- Amended 1990 Ky. Acts ch. 177, sec. 2, effective July 13, 1990. -- Amended 1980 Ky. Acts ch. 270, sec. 1, effective July 15, 1980. -- Amended 1966 Ky. Acts ch. 187, Part I, sec. 2. -- Amended 1954 Ky. Acts ch. 5, sec. 1. -- Recodified 1942 Ky. Acts ch. 208, sec. 1, effective October 1, 1942, from Ky. Stat. secs. 162, 163, 4114h-7.

Notes of Decisions
Cited in 25 cases, 1956–2018 · leading case: City of Somerset v. Bell, 156 S.W.3d 321 (Ky. Ct. App. 2005).
City of Somerset v. Bell, 156 S.W.3d 321 (Ky. Ct. App. 2005). · cites it 46× “But the court concluded that the relief requested by the taxpayers under KRS 134.590 could not be granted because the taxpayers had failed to exhaust certain administrative remedies.”
St. Ledger v. Commonwealth, Revenue Cabinet, 942 S.W.2d 893 (Ky. 1997). · cites it 54× “KRS 134.590 also requires some type of refund under these circumstances as a matter of state law, independent of due process requirements.”
Dep't of Revenue, Fin. & Admin. Cabinet v. Cox Interior, Inc., 400 S.W.3d 240 (Ky. 2013). · cites it 42× “Because of this discovery, Cox Interior filed for a refund under KRS 134.590 in July 2007, sixteen months after it had fully paid the new assessments from the Department’s audit.”
Commonwealth, Revenue Cabinet v. Gossum, 887 S.W.2d 329 (Ky. 1994). · cites it 28× “The circuit court reasoned that inasmuch as the Commonwealth has consented by statute to refund taxes paid under an unconstitutional provision (KRS 134.590), the retroactivity of Davis is essentially a moot question; refunds being in order as a matter of state law.”
Cromwell Louisville Assocs., Ltd. P'ship v. Commonwealth, 323 S.W.3d 1 (Ky. 2010). · cites it 15× “Consequently, the court found that Appellant failed to comply with the mandatory administrative appeals procedures, preventing it from seeking a refund under KRS 134.590 for overpayment of taxes. We also hold Appellant did not comply with the statutory requirements contained in…”
Bd. of Educ. v. Taulbee, 706 S.W.2d 827 (Ky. 1986). · cites it 13× “590(3) provides that a local taxing district may make refunds where the amount of tax paid was in excess of the amount finally determined to be due.”
St. Ledger v. Commonwealth, 912 S.W.2d 34 (Ky. 1995). · cites it 4× “Further, the Circuit Court held that appellants were entitled to apply for refunds of taxes paid for the preceding two year period pursuant to KRS 134.590. The Court of Appeals reversed, holding the exemption statute enforceable and valid.”
Revenue Cabinet v. CSC Oil Co., 851 S.W.2d 497 (Ky. Ct. App. 1993). · cites it 7× “KRS 134.590 provides in pertinent part as follows: (1) When it appears to the appropriate agency of state government that money has been paid into the State Treasury .”
Bischoff v. City of Newport, 733 S.W.2d 762 (Ky. Ct. App. 1987). · cites it 4× “The appellant argues that the circuit court erred in determining (1) that the action could not be prosecuted as a class action, and (2) that compliance with KRS 134.590 was mandatory in order to bring an action for recovery of ad valorem taxes paid.”
City of Bromley v. Smith, 149 S.W.3d 403 (Ky. 2004). · cites it 4× “Thus, it was error for the Court of Appeals to apply KRS 134.590. It was also incorrect in determining that a request for class certification for refund purposes could not be established.”
Light v. City of Louisville, 93 S.W.3d 696 (Ky. Ct. App. 2002). · cites it 5× “590(1) and (2) address the refund of taxes paid to state agencies, while subsections (3) through (6) address the refund of “city, urban-county, county, school district, or special district ad valo-rem taxes.”
Coleman v. Campbell Cnty. Library Bd. of Trs., 901 F. Supp. 2d 925 (E.D. Ky. 2012). · cites it 4× “Specifically, Defendants sought dismissal because Plaintiffs failed to exhaust their administrative remedies prior to filing their lawsuits as mandated by KRS 134.590: No refund for ad valorem taxes, except those held unconstitutional, shall be made unless the taxpayer has…”
— Ky. Rev. Stat. § 134.590(1) — 9 cases
St. Ledger v. Commonwealth, Revenue Cabinet, 942 S.W.2d 893 (Ky. 1997). “KRS 134.590 also requires some type of refund under these circumstances as a matter of state law, independent of due process requirements.”
Bd. of Educ. v. Taulbee, 706 S.W.2d 827 (Ky. 1986). “590(3) provides that a local taxing district may make refunds where the amount of tax paid was in excess of the amount finally determined to be due.”
Dep't of Revenue, Fin. & Admin. Cabinet v. Cox Interior, Inc., 400 S.W.3d 240 (Ky. 2013). “Because of this discovery, Cox Interior filed for a refund under KRS 134.590 in July 2007, sixteen months after it had fully paid the new assessments from the Department’s audit.”
Commonwealth, Revenue Cabinet v. Gossum, 887 S.W.2d 329 (Ky. 1994). “The circuit court reasoned that inasmuch as the Commonwealth has consented by statute to refund taxes paid under an unconstitutional provision (KRS 134.590), the retroactivity of Davis is essentially a moot question; refunds being in order as a matter of state law.”
Revenue Cabinet v. CSC Oil Co., 851 S.W.2d 497 (Ky. Ct. App. 1993). “KRS 134.590 provides in pertinent part as follows: (1) When it appears to the appropriate agency of state government that money has been paid into the State Treasury .”
— Ky. Rev. Stat. § 134.590(2) — 6 cases
Dep't of Revenue, Fin. & Admin. Cabinet v. Cox Interior, Inc., 400 S.W.3d 240 (Ky. 2013). “Because of this discovery, Cox Interior filed for a refund under KRS 134.590 in July 2007, sixteen months after it had fully paid the new assessments from the Department’s audit.”
St. Ledger v. Commonwealth, Revenue Cabinet, 942 S.W.2d 893 (Ky. 1997). “KRS 134.590 also requires some type of refund under these circumstances as a matter of state law, independent of due process requirements.”
Cromwell Louisville Assocs., Ltd. P'ship v. Commonwealth, 323 S.W.3d 1 (Ky. 2010). “Consequently, the court found that Appellant failed to comply with the mandatory administrative appeals procedures, preventing it from seeking a refund under KRS 134.590 for overpayment of taxes. We also hold Appellant did not comply with the statutory requirements contained in…”
Am. Life & Accident Ins. Co. of Kentucky v. Commonwealth, 173 S.W.3d 910 (Ky. Ct. App. 2004).
Am. Life & Acc. Ins. Co. v. Com., 173 S.W.3d 910 (Ky. Ct. App. 2004).
— Ky. Rev. Stat. § 134.590(3) — 3 cases
City of Bromley v. Smith, 149 S.W.3d 403 (Ky. 2004). “Thus, it was error for the Court of Appeals to apply KRS 134.590. It was also incorrect in determining that a request for class certification for refund purposes could not be established.”
Bd. of Educ. v. Taulbee, 706 S.W.2d 827 (Ky. 1986). “590(3) provides that a local taxing district may make refunds where the amount of tax paid was in excess of the amount finally determined to be due.”
Maximum Mach. Co. v. City of Shepherdsville, 17 S.W.3d 890 (Ky. 2000).
— Ky. Rev. Stat. § 134.590(6) — 9 cases
City of Somerset v. Bell, 156 S.W.3d 321 (Ky. Ct. App. 2005). “But the court concluded that the relief requested by the taxpayers under KRS 134.590 could not be granted because the taxpayers had failed to exhaust certain administrative remedies.”
St. Ledger v. Commonwealth, Revenue Cabinet, 942 S.W.2d 893 (Ky. 1997). “KRS 134.590 also requires some type of refund under these circumstances as a matter of state law, independent of due process requirements.”
Commonwealth, Revenue Cabinet v. Gossum, 887 S.W.2d 329 (Ky. 1994). “The circuit court reasoned that inasmuch as the Commonwealth has consented by statute to refund taxes paid under an unconstitutional provision (KRS 134.590), the retroactivity of Davis is essentially a moot question; refunds being in order as a matter of state law.”
Bd. of Educ. v. Taulbee, 706 S.W.2d 827 (Ky. 1986). “590(3) provides that a local taxing district may make refunds where the amount of tax paid was in excess of the amount finally determined to be due.”
Barrett v. Reynolds, 817 S.W.2d 439 (Ky. 1991).
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