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Certificates issued by a political subdivision for
public improvements (such as sewers, sidewalks,
streets, etc.) which are evidence of special
assessments against specific property, which
assessments become a lien against such property and
which the political subdivision is required to enforce,
are, for purposes of this section, obligations of the
political subdivision even though the obligations are
to be satisfied out of special funds and not out of
general funds or taxes. * * *
We have considered petitioner's new arguments and find them
to be without merit. We remain convinced that our prior findings
and opinion in Hernandez I are correct; we decline to alter them
in any respect.
I. Taxation of Real Property in the State of Florida
A brief preliminary discussion of the Florida local property
tax system may be helpful. Taxes are generally imposed on real
property in the form of ad valorem property taxes or special
assessments. Ad valorem taxes are levied uniformly throughout a
taxing district for the general benefit of residents and
property. Sarasota County v. Sarasota Church of Christ, Inc.,
667 So. 2d 180, 183 (Fla. 1995); City of Boca Raton v. State, 595
So. 2d 25, 29 (Fla. 1992). In contrast, special assessments are
usually imposed for a specific purpose to benefit a specific area
or class of property and are imposed only on those properties
that will derive a benefit from the services or improvements made
possible by the special assessment. Sarasota County v. Sarasota
Church of Christ, Inc., supra at 183; City of Boca Raton v.
State, supra at 29.
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