Furst v. DeFrances
A Sarasota County property appraiser back-assessed a taxpayer's waterfront parcel for 2014 after a computer-conversion error caused the parcel to be assessed at roughly $302,400 instead of ~$2.4 million. The Florida Supreme Court, approving the Second District, held that property has 'escaped taxation' under section 193.092(1), Florida Statutes, only when it is not taxed at all — not when it is under-taxed because of a mistaken undervaluation — so the back-assessment was invalid.
Key facts
- A Sarasota County property appraiser back-assessed a taxpayer's waterfront parcel for 2014 after a computer-conversion error caused the property to be valued at approximately $302,400 instead of approximately $2.4 million.
- The property had been placed on the tax roll and taxes were paid on the undervalued amount; the appraiser later discovered the valuation error and sought to assess back taxes based on the corrected higher value.
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Why it matters
This is the Supreme Court's first express construction of 'escaped taxation' in section 193.092(1) and it materially narrows property appraisers' back-assessment authority statewide: undervaluation, even from an… — full analysis with a trial
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