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Florida Statute 193.122 | Lawyer Caselaw & Research
F.S. 193.122 Case Law from Google Scholar
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The 2023 Florida Statutes (including Special Session C)

Title XIV
TAXATION AND FINANCE
Chapter 193
ASSESSMENTS
View Entire Chapter
F.S. 193.122
193.122 Certificates of value adjustment board and property appraiser; extensions on the assessment rolls.
(1) The value adjustment board shall certify each assessment roll upon order of the board of county commissioners pursuant to s. 197.323, if applicable, and again after all hearings required by s. 194.032 have been held. These certificates shall be attached to each roll as required by the Department of Revenue. Notwithstanding an extension of the roll by the board of county commissioners pursuant to s. 197.323, the value adjustment board must complete all hearings required by s. 194.032 and certify the assessment roll to the property appraiser by June 1 following the assessment year. The June 1 requirement shall be extended until December 1 in each year in which the number of petitions filed increased by more than 10 percent over the previous year.
(2) After the first certification of the tax rolls by the value adjustment board, the property appraiser shall make all required extensions on the rolls to show the tax attributable to all taxable property. Upon completion of these extensions, and upon satisfying himself or herself that all property is properly taxed, the property appraiser shall certify the tax rolls and shall within 1 week thereafter publish notice of the date and fact of extension and certification on the property appraiser’s website and in a periodical meeting the requirements of s. 50.011 and publicly display a notice of the date of certification in the office of the property appraiser. The property appraiser shall also supply notice of the date of the certification to any taxpayer who requests one in writing. These certificates and notices shall be made in the form required by the department and attached to each roll as required by the department by rule.
(3) When the tax rolls have been extended pursuant to s. 197.323, the second certification of the value adjustment board shall reflect all changes made by the board together with any adjustments or changes made by the property appraiser. Upon such certification, the property appraiser shall recertify the tax rolls with all changes to the collector and shall provide public notice of the date and fact of recertification pursuant to subsection (2).
(4) An appeal of a value adjustment board decision pursuant to s. 194.036(1)(a) or (b) by the property appraiser shall be filed prior to extension of the tax roll under subsection (2) or, if the roll was extended pursuant to s. 197.323, within 30 days of recertification under subsection (3). The roll may be certified by the property appraiser prior to an appeal being filed pursuant to s. 194.036(1)(c), but such appeal shall be filed within 20 days after receipt of the decision of the department relative to further judicial proceedings.
(5) The department shall promulgate regulations to ensure that copies of the tax rolls are distributed to the appropriate officials and maintained as part of their records for as long as is necessary to provide for the orderly collection of taxes. Such regulations shall also provide for the maintenance of the necessary permanent copies of such rolls.
(6) The property appraiser may extend millage as required in subsection (2) against the assessment roll and certify it to the tax collector even though there are parcels subject to judicial or administrative review pursuant to s. 194.036(1). Such parcels shall be certified and have taxes extended against them in accordance with the decisions of the value adjustment board or the property appraiser’s valuation if the roll has been extended pursuant to s. 197.323, except that payment of such taxes by the taxpayer shall not preclude the taxpayer from being required to pay additional taxes in accordance with final judicial determination of an appeal filed pursuant to s. 194.036(1).
(7) Each assessment roll shall be submitted to the executive director of the department in the manner and form prescribed by the department within 1 week after extension and certification to the tax collector and again after recertification to the tax collector, if applicable. When the provisions of s. 193.1145 are exercised, the requirements of this subsection shall apply upon extension pursuant to s. 193.1145(3)(a) and again upon reconciliation pursuant to s. 193.1145(8)(a).
History.s. 18, ch. 70-243; s. 1, ch. 71-371; s. 9, ch. 73-172; s. 4, ch. 74-234; s. 2, ch. 76-133; s. 5, ch. 76-234; s. 1, ch. 77-174; s. 14, ch. 82-226; s. 2, ch. 82-388; ss. 3, 26, ch. 83-204; s. 55, ch. 83-217; ss. 208, 221, ch. 85-342; s. 141, ch. 91-112; s. 976, ch. 95-147; s. 3, ch. 2013-72; s. 3, ch. 2016-128.
Note.Consolidation of provisions of former ss. 193.401-193.421.

F.S. 193.122 on Google Scholar

F.S. 193.122 on Casetext

Amendments to 193.122


Arrestable Offenses / Crimes under Fla. Stat. 193.122
Level: Degree
Misdemeanor/Felony: First/Second/Third

Current data shows no reason an arrest or criminal charge should have occurred directly under Florida Statute 193.122.



Annotations, Discussions, Cases:

Cases from cite.case.law:

SOWELL, v. FAITH CHRISTIAN FAMILY CHURCH OF PANAMA CITY BEACH, INC., 249 So. 3d 1323 (Fla. App. Ct. 2018)

. . . assessment within "60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

WILLIAMS ISLAND VENTURES, LLC, v. DE LA MORA,, 246 So. 3d 471 (Fla. App. Ct. 2018)

. . . Section 193.122(1), Florida Statutes (2014), makes only the VAB responsible for making the final certification . . .

R. NIKOLITS, v. L. HANEY, W. M., 221 So. 3d 725 (Fla. Dist. Ct. App. 2017)

. . . As required by section 193.122(3), Florida Statutes (2010), the property appraiser re-certified the tax . . . decision, the property appraiser filed an original action in the circuit court pursuant to sections 193.122 . . .

CITY OF MIAMI, v. NW STREET, LLC,, 217 So. 3d 143 (Fla. Dist. Ct. App. 2017)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

S. MILES, v. PARRISH,, 199 So. 3d 1046 (Fla. Dist. Ct. App. 2016)

. . . evidence proving the date on which the taxes and penalties were “certified for collection under s. 193.122 . . . The version of section 193.122(2) applicable to this case stated: After the first certification of the . . . Under section 193.122(2), a property appraiser must, after first completing any necessary extensions, . . . certify the tax rolls “upon satisfying himself or herself that all property is properly taxed.” § 193.122 . . . (2);” A tax lien is not a tax assessment, and it is not certified for collection under section 193.122 . . .

SOWELL, v. PANAMA COMMONS L. P., 192 So. 3d 27 (Fla. 2016)

. . . See §§ 193.122(1)-(3); 197.322(1)-(2); 197.323(1), Fla. Stat. (2013). . . .

GENESIS MINISTRIES, INC. v. S. BROWN, As As As, 186 So. 3d 1074 (Fla. Dist. Ct. App. 2016)

. . . such actions to be filed within 60 days after the assessment is “certified for collection under si 193.122 . . . A tax lien is not a tax 'assessment, and it is not certified for collection under section 193.122(2). . . . Section 193.122 has nothing to do with tax liens.' . . . lien after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . . issues of fact as to whether the property appraiser complied with the notice requirements in section 193.122 . . .

R. NIKOLITS, v. B. NEFF, a k a B. a k a B., 184 So. 3d 538 (Fla. Dist. Ct. App. 2015)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

STRANBURG, v. PANAMA COMMONS L. P., 160 So. 3d 160 (Fla. Dist. Ct. App. 2015)

. . . See §§ 193.122(l)-(3); 197.322(l)-(2); 197.323(1), Fla. Stat. (2013). . . .

In READ, v., 692 F.3d 1185 (11th Cir. 2012)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

In READ, v., 692 F.3d 1185 (11th Cir. 2012)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

SOUTH POINTE FAMILY CHILDREN CENTER, INC. a v. MIAMI- DADE COUNTY,, 57 So. 3d 256 (Fla. Dist. Ct. App. 2011)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

VILLAGE OF DORAL PLACE ASSOCIATION, INC. v. REAL, INC. W., 22 So. 3d 627 (Fla. Dist. Ct. App. 2009)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s.193.122 . . .

P. CASON, v. FLORIDA DEPARTMENT OF MANAGEMENT SERVICES,, 944 So. 2d 306 (Fla. 2006)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

HIDDEN BAY MASTER ASSOCIATION, INC. v. MIAMI- DADE COUNTY DEPARTMENT OF PROPERTY APPRAISAL, MTAG LLC, V LLC,, 938 So. 2d 599 (Fla. Dist. Ct. App. 2006)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

STATE DEPARTMENT OF MANAGEMENT SERVICES, v. P. CASON, COLUMBIA COUNTY, W. a k a W. a k a O., 909 So. 2d 378 (Fla. Dist. Ct. App. 2005)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

In CABLE WIRELESS USA, INC., 331 B.R. 568 (Bankr. D. Del. 2005)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under 193.122 . . .

HIGGS, Co. v. ARMADA KEY WEST LTD. PARTNERSHIP,, 903 So. 2d 303 (Fla. Dist. Ct. App. 2005)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

WARD, v. BROWN,, 894 So. 2d 811 (Fla. 2004)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . . an assessment roll subsequent to certification of that roll to the tax collector pursuant to section 193.122 . . .

PRIMECO PERSONAL COMMUNICATIONS, L. P. a d b a v. MASTROIANNI, ARC IV, LLC, a v., 837 So. 2d 1157 (Fla. Dist. Ct. App. 2003)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . . court, however, accepted Mastroianni’s argument that the time for filing was controlled by section 193.122 . . . these facts, the circuit court filings were untimely under section 194.171(2) but timely under section 193.122 . . . Section 193.122(4) sets out the time limits within which the property appraiser may appeal a decision . . . This interpretation gives a field of operation to both statutory sections and avoids rendering section 193.122 . . .

FLORIDA GOVERNMENTAL UTILITY AUTHORITY, v. DAY,, 784 So. 2d 494 (Fla. Dist. Ct. App. 2001)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

DEPARTMENT OF REVENUE, v. EASTERN AMERICAN TECHNOLOGIES CORPORATION,, 762 So. 2d 1044 (Fla. Dist. Ct. App. 2000)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

PALM BEACH GARDENS COMMUNITY HOSPITAL, INC. a v. NIKOLITS, K. H., 754 So. 2d 729 (Fla. Dist. Ct. App. 1999)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

WAL- MART STORES, INC. v. M. DAY,, 742 So. 2d 408 (Fla. Dist. Ct. App. 1999)

. . . One week later, as required by section 193.122(3), the property appraiser recerti-fied the tax rolls . . . Thus, Walker recognized the interrelationship of sections 197.323, 193.122, and 194.171(2). . . . The property appraiser then recertified the entire tax rolls as set forth in section 193.122(3). . . . See § 193.122(2), Fla. Stat. (1997). . . . That case involved the 1981 version of section 193.122 and section 194.171. . . .

R. NIKOLITS, K. H. v. S. BALLINGER, A. THE WYNNE, 736 So. 2d 1253 (Fla. Dist. Ct. App. 1999)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under § 193.122 . . .

SARTORI d b a v. DEPARTMENT OF REVENUE, 714 So. 2d 1136 (Fla. Dist. Ct. App. 1998)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

PALMER TRINITY PRIVATE SCHOOL, INC. v. W. ROBBINS,, 681 So. 2d 809 (Fla. Dist. Ct. App. 1996)

. . . after 60 days from the date the assessment being contested is certified for collection under section 193.122 . . .

STATE DEPARTMENT OF REVENUE, v. RAY CONSTRUCTION OF OKALOOSA COUNTY,, 667 So. 2d 859 (Fla. Dist. Ct. App. 1996)

. . . assessment “after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . . Section 193.122(2) required the property appraiser to certify the tax rolls and “within 1 week thereafter . . .

T. HALL, v. LEESBURG REGIONAL MEDICAL CENTER,, 651 So. 2d 231 (Fla. Dist. Ct. App. 1995)

. . . after 60 days from the date the assessment being contested is certified for collection under section 193.122 . . .

STATE DEPARTMENT OF REVENUE E. v. L. STAFFORD,, 646 So. 2d 803 (Fla. Dist. Ct. App. 1994)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

A. JOYNER v. ROBERTS,, 642 So. 2d 826 (Fla. Dist. Ct. App. 1994)

. . . DCA 1994), that a property appraiser’s failure to adhere strictly to the notice provisions in section 193.122 . . . Section 193.122(2), Florida Statutes (1991) provides: After the first certification of the tax rolls . . . 233, ever began, on a rationale that applies with equal or greater force here: In drafting section 193.122 . . . Moriarty, 575 So.2d 1307, 1310 (Fla. 4th DCA 1991) (holds that the notice requirements of section 193.122 . . . also supply notice of the date of the certification to any taxpayer who requests one in writing.” § 193.122 . . .

A. CHIHOCKY, v. Ed CRAPO,, 632 So. 2d 230 (Fla. Dist. Ct. App. 1994)

. . . and extension of the tax roll for 1990 in the Office of the Property Appraiser as required by section 193.122 . . . Section 193.122(2) provides as follows: [U]pon satisfying himself that all property is properly taxed . . . the 60-day period begins to run from the certification of the tax roll for collection under section 193.122 . . . In drafting section 193.122(2), the Legislature went to considerable lengths to ensure, as far as practical . . . Moriarty, 575 So.2d 1307, 1310 (Fla. 4th DCA 1991) (holds that the notice requirements of section 193.122 . . .

E. WALKER, v. A. GARRISON,, 610 So. 2d 716 (Fla. Dist. Ct. App. 1992)

. . . , as property appraiser of Palm Beach County, initially certified the tax rolls pursuant to section 193.122 . . . On March 13, 1992, as required by section 193.122(3), Florida Statutes, petitioner recertified the tax . . . the sixty day filing period commences to run at the time of the initial certification under section 193.122 . . . petitioner contends, or whether it commences to run at the time of the recertification under section 193.122 . . . The recertification of the rolls under section 193.122(3) has no bearing on the time limits of section . . .

H. W. SUBER, v. KELLEY,, 592 So. 2d 805 (Fla. Dist. Ct. App. 1992)

. . . Section 193.122(4), Florida Statutes (1989) discusses appeals of value adjustment board decisions and . . .

ROBBINS v. DEBARTOLO LDS CV,, 48 Fla. Supp. 2d 152 (Fla. Cir. Ct. 1991)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under § 193.122 . . .

MARKHAM, v. W. MORIARTY,, 575 So. 2d 1307 (Fla. Dist. Ct. App. 1991)

. . . The property appraiser then recer-tified the entire tax rolls as set forth in section 193.122(3). . . . Section 193.122 provides in part as follows: (emphasis added) (1) The property appraisal adjustment board . . . Respondent contends that the notice requirements of section 193.122(2), Florida Statutes, do not comport . . . Furthermore, section 193.122(2), Florida Statutes provides a means whereby a taxpayer can receive actual . . .

ROBBINS v. CAPO,, 42 Fla. Supp. 2d 162 (Fla. Cir. Ct. 1990)

. . . affirmatively demonstrate that his complaint was timely filed, well within the limitation imposed by section 193.122 . . .

BAUMANN v. ROBBINS,, 38 Fla. Supp. 2d 129 (Fla. Cir. Ct. 1989)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under § 193.122 . . .

TOWER MEDICAL GROUP, INC. v. ROBBINS,, 37 Fla. Supp. 2d 135 (Fla. Cir. Ct. 1989)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under § 193.122 . . .

PALM SPRINGS MILE ASSOCIATES, LTD. v. ROBBINS,, 43 Fla. Supp. 2d 158 (Fla. Cir. Ct. 1989)

. . . “appeal” may be brought is governed not by § 194.171(2), admittedly a statute of nonclaim, but by § 193.122 . . . Fla. 1987), the Third District distinguished between the two aformentioned statutes, specifying that 193.122 . . . Court concludes that the Property Appraiser’s counterclaim is governed not by § 194.171(2), but by § 193.122 . . . Compare § 193.122(4), Florida Statutes (1987) (“An appeal of a property appraisal adjustment board decision . . .

BELL, III, R. v. BRYAN, D. B. W. O. H., 519 So. 2d 1024 (Fla. Dist. Ct. App. 1988)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

SEITLIN, v. B. BYSTROM,, 514 So. 2d 368 (Fla. Dist. Ct. App. 1987)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

B. BYSTROM, v. FLORIDA ROCK INDUSTRIES, INC., 502 So. 2d 35 (Fla. Dist. Ct. App. 1987)

. . . certification violated Bystrom’s “mandatory duty to certify the tax roll in accordance with section 193.122 . . . At the time material to this appeal, section 193.122(2), Florida Statutes (1979), required that: After . . . lawsuit under section 194.-032(6)(a)(l) or (2), and falls within the time limitations set by section 193.122 . . . We note that section 193.122 states that “upon satisfying himself that all property is properly taxed . . . Thus, Bystrom had the mandatory duty to certify the tax rolls in accordance with section 193.122, Florida . . .

INTERNATIONAL SOCIETY FOR KRISHNA CONSCIOUSNESS, v. BYSTROM,, 15 Fla. Supp. 2d 17 (Fla. Cir. Ct. 1985)

. . . when it (PAAB) certified that assessment to the Dade County Property Appraiser pursuant to Section 193.122 . . .

F. REDFORD, Jr. G. B. B. v. DEPARTMENT OF REVENUE,, 478 So. 2d 808 (Fla. 1985)

. . . the department requested that the appraiser appeal the board’s decisions in accordance with sections 193.122 . . .

B. BYSTROM, v. FLORIDA ROCK INDUSTRIES, INC., 452 So. 2d 1053 (Fla. Dist. Ct. App. 1984)

. . . On the first point, we construe Section 193.122(1) and (4), Florida Statutes (1981) as requiring that . . . Section 193.122(1) and (4), Florida Statutes (1981) provides in pertinent part: (1) The property appraisal . . .

E. REDFORD, Jr. G. B. B. v. STATE DEPARTMENT OF REVENUE,, 452 So. 2d 961 (Fla. Dist. Ct. App. 1984)

. . . thereafter, the Appraiser also certified the tax roll containing the exemption in accordance with section 193.122 . . .

COWART, v. PERKINS, A., 445 So. 2d 654 (Fla. Dist. Ct. App. 1984)

. . . after sixty days from the date the assessment being contested is certified for collection under s. 193.122 . . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

MANASOTA BURIAL PARKS, INC. v. PERKINS, MANASOTA MEMORIAL PARK, INC. v. PERKINS,, 440 So. 2d 479 (Fla. Dist. Ct. App. 1983)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

MILLER, v. C. NOLTE,, 427 So. 2d 248 (Fla. Dist. Ct. App. 1983)

. . . Pursuant to section 193.122(2), Florida Statutes (1981), the assessment was certified for collection . . . assessment after 60 days from the date the assessment being contested is certified for collection under § 193.122 . . .

Ed WILSON, V. Sr. v. SCHOOL BOARD OF MARION COUNTY,, 424 So. 2d 16 (Fla. Dist. Ct. App. 1982)

. . . was apparently filed before the tax assessment had been certified for collection pursuant to section 193.122 . . .

ST. JOE PAPER COMPANY B. v. METROPOLITAN DADE COUNTY, a A. H. B. W. Jr. L., 418 So. 2d 1013 (Fla. Dist. Ct. App. 1982)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

F. B. BYSTROM, v. EQUITABLE LIFE ASSURANCE SOCIETY OF UNITED STATES, a a, 416 So. 2d 1133 (Fla. Dist. Ct. App. 1982)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

CAPE CAVE CORPORATION, a v. LOWE, L., 411 So. 2d 887 (Fla. Dist. Ct. App. 1982)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . . Section 193.122(1), Florida Statutes (1979) requires that this certification be performed only “after . . .

DEPARTMENT OF REVENUE v. GOEMBEL v. TOMPKINS LAND COMPANY, INC., 382 So. 2d 783 (Fla. Dist. Ct. App. 1980)

. . . tax assessment after sixty days from the date the assessment roll is certified for collection under § 193.122 . . .

WILLIAMS, v. LAW, 368 So. 2d 1285 (Fla. 1979)

. . . assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122 . . .

A. H. BLAKE, v. R. M. S. HOLDING CORP. a, 341 So. 2d 795 (Fla. Dist. Ct. App. 1977)

. . . assessment after 60 days from the date the assessment roll is certified for collection under section 193.122 . . .

R. R. WALDEN, v. UNIVERSITY OF TAMPA, INCORPORATED, a, 304 So. 2d 134 (Fla. Dist. Ct. App. 1974)

. . . assessment after 60 days from the date the assessment roll is certified for collection under section 193.122 . . .

HOLLYWOOD JAYCEES v. STATE DEPARTMENT OF REVENUE,, 306 So. 2d 109 (Fla. 1974)

. . . entered April 8, 1974 denying petition for a rehearing which directly upheld the validity of Section 193.122 . . . Appellants herein filed a motion for summary judgment attacking the constitutionality of Section 193.122 . . . Section 193.122(1), F.S., as amended, is facially valid but was given an unconstitutional application . . .

FLORIDA EAST COAST RAILWAY COMPANY, v. L. REID,, 281 So. 2d 77 (Fla. Dist. Ct. App. 1973)

. . . the plaintiff, and, when the roll was certified by the assessor on 13 October 1971, as required by § 193.122 . . . 60 days from 13 October 1971 — the date the tax roll was certified by the tax assessor under F.S. § 193.122 . . . suit is instituted within sixty days from the time the assessment roll is certified as provided in § 193.122 . . .

O D. ASKEW, v. MGIC DEVELOPMENT CORPORATION OF FLORIDA, a, 262 So. 2d 227 (Fla. Dist. Ct. App. 1972)

. . . The only support appellee has for this argument is Section 193.122(1), F.S.1970, F.S.A., which became . . . Section 193.122(1), F.S.1970, F.S.A., refers to certification by the Board of Tax Adjustment, and allows . . . However, the certification by the tax assessor, as provided in Section 193.122(2), is the event which . . . It refers to Section 193.122(1), whereas the Session Law (Section 30, Chap. 70-243) makes reference to . . . Section 193.122(2). . . .

SHERRY FRONTENAC, v. TAX ASSESSOR,, 35 Fla. Supp. 140 (Dade Cty. Cir. Ct. 1971)

. . . 193.381, relating to certification) and has consolidated those statutes in a section now codified as §193.122 . . . The exclusion of tax assessments in arbitration from the certification process by §193.122 was therefore . . .