Does Property Improvement Assessment Serve As An Exception for Property Assessed at Fair Market Value ?

In Culbertson v. Seacoast Towers East, Inc., 212 So. 2d 646 (Fla. 1968) the Court rejected the claim that the predecessor substantially complete statute constituted an exception to the "just valuation" requirement. The Court recognized that the statute did not create an exception to the constitutional requirement that property be assessed at its fair market value but, instead, determined the time at which property improvements should be assessed (i.e., when they are substantially complete). Id. The terms "fair market value" and "just valuation" are synonymous in this context. See Walter v. Schuler, 176 So. 2d 81, 85-86 (Fla. 1965).