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Filing # 70815135 E-Filed 04/17/2018 11:59:48 AM
IN THE CIRCUIT COURT OF THE ELEVENTH
JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CIVIL ACTION
RAUL MEJIA, and VIRGINIA LOPEZ
Plaintiffs,
CASE NO.:
vs. DIVISION:
PEDRO LOPEZ, as Property Appraiser of
Miami Dade County Florida; LEON M.
BIEGALSKI, as Executive Director of
Florida Department of Revenue; MARCUS
SAIZ DE LA MORA, as Tax Collector of
Miami Dade County, Florida
Defendants.
/
COMPLAINT FOR DECLARATORY RELIEF
COMES NOW Plaintiffs, RAUL MEJIA (hereinafter, MEJIA) and VIRGINIA
LOPEZ (hereinafter, LOPEZ), as Joint Tennant with Rights of survivorship, (hereinafter,
“PLAINTIFFS”) and sues Defendants, PEDRO LOPEZ, as Property Appraiser of Miami
Dade County Florida, (hereinafter “Appraiser”); LEON M. BIEGALSKI, as Executive
Director of Florida Department of Revenue, (hereinafter, “DOR”); and MARCUS SAIZ DE
LA MORA, as Tax Collector of Miami Dade County, Florida (hereinafter, “Collector’); the
Collector, DOR, and Appraiser are hereinafter jointly referred to as Defendants, and allege:
NATURE OF THE CASE
1. This is an action for a declaratory judgment and to challenge the removal and
refusal to reinstate of a homestead and Senior Citizen exemptions (hereinafter,
“Exemptions”) and imposition of retroactive tax liens on property in Miami-Dade County,
Florida.
PARTIES
2. Plaintiffs, MEJIA and LOPEZ, at all times relevant, are the owners of certain real
Page 1 of 13property located at 201 178th Drive, unit 531, Sunny Isles, Florida 33160-2875, and
identified as Parcel No. 31-2211-089-1220 (“Subject Property”), which was classified and
assessed as owner-occupied residential property in tax year 2005 through 2016.
3. Appraiser is sued herein in his official capacity and is a necessary party to this
action pursuant to section 194.181(2), Florida Statutes.
4. Collector is sued herein in his official capacity and is a necessary party to the action
pursuant to section 194.181(3), Florida Statutes.
5. Defendant, LEON M. BIEGALSKI, is sued herein in his official capacity and is a
necessarily party to the action pursuant to section 194.181(5), Florida Statutes.
JURISDICTION
6. This Court has jurisdiction pursuant to Chapter 194, Florida Statutes, article V,
sections 5 and 20 of the Florida Constitution, and section 86.011, Florida Statutes.
VENUE
7. Venue is appropriate in this Court pursuant to Fla. Stat. Sections 47.011, and
47.021.
GENERAL ALLEGATIONS
8. Plaintiffs jointly owned the Subject Property from 2005 through and including the
present which consisted of a single residential or family unit and made it their permanent
residence.
9. Except for tax year 2013, from 2005 through and including tax year 2017, the
Plaintiffs have occupied and used the Subject. Property predominantly or exclusively as
their homestead.
10. The Plaintiffs applied for and received a homestead exemption on the subject. in
2005 which was automatically renewed through 2012; however, on or about August 29,
2018, MEJIA visited the Property Appraiser’s office and informed them that the property
Page 2 of 13was rented from April 2012 to April 2013 and sought to renew and reapply for the
exemption to commence tax year 2014.
11. While at the property appraiser's office, MEJIA was informed that he may be
eligible for a Senior Citizen Exemption. The agent assisted MEJIA with completing the
forms. MEJIA had no intent to seek an exemption for 2013, however, the Agent completed
the form as a late application for exemption. This was error.
12. On December 5, 2016, the Appraiser made a determination that the Plaintiffs “were
not entitled to the Homestead Exemption” on the Subject Property and issued a Notice of
Intent to Lien the subject property for tax years 2011 through 2015. See Exhibits A
attached hereto
13. Upon the Plaintiffs contest of the determination and Notice of Intent to Lien for tax
years 2011 through 2015, the Appraiser reversed its position with respect to tax years 2011
and 2012, but maintained their position with respect to tax years 2018 through 2015. See
Exhibit C attached hereto
14, Again, on July 3, 2017, the Appraiser made a determination that the Subject
Property and Plaintiffs “were not entitled to the Homestead Exemption” and issued a
Notice of Intent to Lien the subject property for tax years 2016. See Exhibits B and D
attached hereto
15. On information from the Appraiser, the specific basis for the removal of the
exemptions for years 2013 through 2016 is as follows:
a. For tax year 2013 the Appraiser states that based on a rental contract produced
by the Plaintiff to the Appraiser, the property was not being used as a
homestead.
b. For tax years 2014 through 2016 the Appraiser states that the Plaintiffs failed to
reapply for the exemptions which was removed in 2013; however, the DR-453
Page 3 of 13forms supplied by the Property Appraiser states that the exemptions were being
denied and the retroactive tax levied as a result of “Rental of Homestead.”
16. The Plaintiffs do not contest the removal of the exemptions as it relates to tax year
2018 and as such has paid the Retroactive Tax; however, the Plaintiffs maintain that the
levy of interest and penalties for tax year 2013 is not supported by law and the facts. See
Exhibit E attached hereto
17. On or about August 29, 2013 when MEJIA visited the Appraiser’s office and applied
for Senior Citizenship Exemptions pursuant to Fla. Stat. 196.075 in addition to notifying
the Property Appraiser of the loss of 2013 exemption and seeking to apply for the 2014
homestead exemption. This Senior Citizen Exemption application was an_ initial
application which necessarily accompanied and required that the Subject Property be
declared the homestead.
18.The property appraiser granted retroactive benefits to the Senior Citizenship
Exemption application for tax year 2013 and future years although MEJIA informed them
of the loss of Homestead for 2013 and sought only 2014 forward.
19. As at April 17, 2018, the subject property was no longer under contract for rental
and was being used as the Plaintiffs’ homestead which entitled them to exemptions for tax
years 2014 through present.
20. The application for senior citizenship exemption on August 29, 2018, although late
for tax year 2018, was timely received for tax year 2014.
21.The Plaintiffs own no other property on which to claim or receive a homestead
exemption or Senior Citizen Exemption in the state of Florida or any other state.
22. The Plaintiffs have provided the Defendants with all documents to establish that the
subject property is their homestead, yet the Appraiser maintains the same position that the
subject property is being rented and that the taxpayers have failed to provide statutory
Page 4 of 13evidence that the Subject Property is their permanent address. This position of the
Property Appraiser is unsupported by the facts and law.
23. An actual case and controversy exists between the parties that may be adjudicated
by this Court.
24.The Defendants have taken affirmative action against Plaintiffs by placing a lien
against their property.
25. Plaintiffs have a reasonable apprehension that it will suffer irreparable injury if the
Defendants does to release the lien against their property because interest continues to
accrue and the property is in jeopardy of eventual say by the defendants to satisfy the liens.
26.The Defendants demanded that Plaintiffs pay the Liens (including interest and
penalties) resulting from the removal of Exemptions, to which Exemptions the Plaintiffs are
entitled.
27. Plaintiffs have a real and reasonable apprehension that if they should fail to pay the
Lien they will be penalized by the Defendants and their Subject Property would be taken
and used to satisfy said Lien.
28.The Declarations sought herein is necessary and appropriate under the
circumstances in order that Plaintiffs may ascertain Exemptions to which they are entitled
and the correct amount of recapture tax, penalties and interest, if any, permissible by law.
29. Pursuant to Fla. Stat. § 86.011 this Court has jurisdiction to declare the existence or
nonexistence of any fact upon which the existence or nonexistence of an immunity, power,
privilege, or right does or may depend, whether such immunity, power, privilege, or right
now exists or will arise in the future.
30. Pursuant to Fla. Stat. § 86.051 allows the Court to render a declaratory judgment by
way of anticipation with respect “to any act not yet done or any event which has not yet
happened.”
Page 5 of 1331, Pursuant to Fla. Stat. § 86.111 also permits “a speedy hearing of an action for
declaratory judgment” and the Court “may advance it on the calendar.”
32. Pursuant to Fla. Stat. § 86.101 provides that this Court has jurisdiction to address
the instant matter to settle and to afford relief from insecurity and uncertainty with respect
to rights, status, and other equitable or legal relations.
33. The failure to stop the Defendant’s past and present course of conduct as set forth
herein would be to endorse an injustice and loss of the plaintiffs property, and monies paid
under protest so as to establish standing for this action.
34. Prior to instituting this action, the Plaintiffs:
a. Paid under protest the entire recapture tax levy with interest and penalties for
tax year 2013; See Exhibit E attached hereto
b. Paid under protest the amount of the recapture tax for tax years 2014 through
2016 as good faith payment which exceeds the amount the recapture tax when
the exemptions are reinstated and/or the amount of interest and penalties are
removed; See Exhibit F attached hereto
c. Paid the 2017 tax bill under protest. See Exhibit G attached hereto
35. All conditions precedent to filing this suit have been met.
COUNT I - REMOVAL OF TAX LIEN
(As to Tax Years 2014 through 2016)
36. Plaintiffs reassert and reaffirms the allegations of paragraphs 1 through 35 as if
fully set forth herein, and further states:
37. On December 5, 2016 and July 3, 2017, the Appraiser sent the Plaintiffs a Notice of
Intent to File Lien (hereinafter “Lien Notices”) notifying them that the homestead and
senior citizenship exemptions on the Subject Property would be retroactively removed for
the 2011-2015 and 2016 tax years respectively. Copies of the Liens are attached hereto as
Page 6 of 13Exhibits A through D, H and I.
38. The Lien Notices stated that the reason for the removal of the Exemptions was due
to rental of the homestead. See Exhibit A at 2, and Exhibit B at 2
39. Consistent with the Lien Notices, the Appraiser and Collector recorded the tax liens
against the Subject Property.
40. Section 196.161, Florida Statutes allows the Property Appraiser to file a tax lien
against property of a taxpayer who was granted Exemption to which they were not entitled
for any year or years within the prior 10 years, to recapture said taxes, and to assess
penalties thereon.
Al. Under section 196.061 and consistent with section 196.198(8),(4), Florida Statutes,
“In order for there to be entitlement to a homestead tax exemption, an individual must
show ownership of the home, residence therein, and the making of such residence as the
permanent home in good faith.” See AGO 2008-18, 2008 Fla. AG LEXIS 14.
42. The Plaintiffs have resided in the subject property as their permanent home since
April 17, 2013.
43. The Plaintiffs applied for exemption in August 2013 with sufficient time to obtain
the exemptions for tax years 2014 and subsequent years, thus the Plaintiffs were entitled to
the Exemption on the Subject Property in the 2014 through 2016 tax years, pursuant to
article VII, section 6 of the Florida Constitution and section 196.031, Florida Statutes.
Thus, the Property Appraiser's retroactive removal of the homestead exemption and
imposition of a tax lien was unlawful.
44. The Subject Property was being used as the Plaintiff's permanent residence for tax
years 2014 through 2016, thus it is contrary to law to deny the Plaintiff's the Exemptions
and to levy retroactive tax thereon.
WHEREFORE, Plaintiffs request that this Court enter an order reinstating the
Page 7 of 132014 through 2016 homestead and senior citizen exemptions on the subject property;
cancelling the tax lien; order the refund of all overpayments, awarding Plaintiffs their costs
incurred in bringing this action pursuant to section 194.192, Florida, and any other remedy
the court deems just and proper.
COUNT II - Removal of Tax Lien Interest and Penalties
(As to Tax Years 2014-2016)
45, Plaintiffs reassert and reaffirms the allegations of paragraphs 1 through 35 as if
fully set forth herein, and further states:
46. On December 5, 2016 and July 3, 2017, the Appraiser sent the Plaintiffs a Notice of
Intent to File Lien (hereinafter “Lien Notices”) notifying them that the homestead and
senior citizenship exemptions on the Subject Property would be retroactively removed for
the 2011-2015 and 2016 tax years respectively. Copies of the Liens are attached hereto as
Exhibits A through D, H and I.
47. Section 196.161, Florida Statutes allows the Property Appraiser to file a tax lien
against property of a taxpayer who was granted Exemption to which they were not entitled
for any year or years within the prior 10 years, to recapture said taxes, and to assess
penalties and interest thereon.
48. Under section 196.061 and consistent with Fla. Stat. § 196.193(3),(4), “In order for
there to be entitlement to a homestead tax exemption, an individual must show ownership
of the home, residence therein, and the making of such residence as the permanent home in
good faith. See AGO 2008-18, 2008 Fla. AG LEXIS 14.
49. The Subject Property was not being rented in tax years 2014 through 2016 and the
plaintiffs resided therein as their permanent and primary residence.
50. In discussions with the Appraiser, the Appraiser’s position is that the Plaintiffs
failed to apply for their Exemptions for the tax years subsequent to the 2013 tax year of the
Page 8 of 13removal of the exemption; however, the notices indicate that the exemptions were removed
due to rental of the homestead. The Appraiser’s position is that the Plaintiffs failed to
reapply for their exemptions and is thus subject to a lien for penalties.
51. Even assuming arguendo that the Plaintiffs did not timely apply or failed to apply
for Exemptions on the Subject Property for tax years 2014 through 2016, a position the
plaintiffs dispute, there is no basis for the assessment of penalties in tax years 2014
through 2016 because the Plaintiffs were entitled to the exemption as a matter of law.
Absent wrongdoing in obtaining an exemption, there is no basis in law to assess penalties
and interest. Moreover, notwithstanding mere entitlement, the Plaintiffs did apply for the
exemption in time for the 2014 tax year.
52. Since the Property was not being rented, the Plaintiffs were entitled to the
Exemptions under Fla. Stat. §§ 196.161(b) and 196.011 because the property was not being
used for a non-exempt purpose and the plaintiffs did not defraud the Defendants to obtain a
benefit to which they were otherwise entitled.
53. Even if the Plaintiffs had failed to apply for Exemptions for tax years 2014, which
they did not, the Plaintiffs were entitled to the exemptions, thus the recapture of a tax for
failure to apply for Exemptions which the property appraiser granted is not a basis under
Fla. Stat. § 196.161(1)() to assess penalties and interest. Had the Plaintiffs simply failed
to apply for the Exemptions to which they are entitled, they would simply not the granted
the exemptions, but no penalty or interest under Fla. Stat. § 196.161 can be levied for
failure to make an application because there is no basis to establish a lack of entitlement.
54. The Plaintiffs were permanent residents of the state of Florida and resided in the
Subject Property in tax years 2014 through 2016, as such there is no wrongdoing to denying
them of entitlement to the homestead exemption, thus there can be no interest or penalty
assessed under Fla. Stat. § 196.161.
Page 9 of 1355. For interest and penalties to be assessed on a recapture tax pursuant to Fla. Stat. §
196.161, the Property owners must first be determined to be “a person who was not entitled
to a homestead exemption [and] was granted a homestead exemption from ad valorem
taxes.”
56. The triggering event for the levy of interest and penalties under Fla. Stat. §
196.161(1)(b) is a lack of entitlement; not whether an application for said exemptions to
which the Plaintiffs are otherwise entitled, was filed. Thus, even assuming arguendo that
the Plaintiffs had not applied for the exemptions after 2013, which is not the case, the
plaintiffs were entitled to the exemptions because the use of the property dictated the
“entitlement.”
57. Entitlement under the statute is a matter of actual entitlement to claim the
exemption. See Mitchell v. Higgs, 61 So. 3d 1152, 1155 (Fla. 3 DCA 2011) (“The
legislature has imposed a series of requirements for eligibility for the homestead tax
exemption and a mechanism for recovering the tax savings (plus interest and a penalty)
realized by a property owner not actually entitled to claim the exemption.”)
58. For the penalties to be levied, the Plaintiffs would necessarily have had to receive
the homestead exemption unlawfully. See also, Fla. Stat. § 196.161(8) (Such lien when filed
shall attach to any property which is identified in the notice of lien and is owned by the
person who illegally or improperly received the homestead exemption.)
59. With respect to 2014 through 2016, where there is no rental of the homestead
property, the levy of penalty is contrary to law because the Plaintiffs did not obtain the
homestead exemption illegally.
60. Moreover, and consistent with the foregoing, Fla. Stat. § 196.161(1)(b) provides, “if a
homestead exemption is improperly granted as a result of a clerical mistake or an
omission by the property appraiser, the person improperly receiving the exemption shall
Page 10 of 13not be assessed penalty and interest.”
61. Consistent with Fla. Stat. § 196.161(1)(b), Fla. Stat. Fla. Stat. § 196.161(8) requires
that an improper receipt pf a homestead exemption would also result in a lien for the
recapture tax, however, the improper receipt of the homestead is as defined in Fla. Stat. §
196.161(1)(b).
62. The Plaintiffs were actually entitled to claim the exemptions and in fact took steps
to claim exemptions in August 2013 in time for the 2014 tax year.
63. Even assuming arguendo that the plaintiffs failed to apply for the exemption, the
levy of penalties for tax year 2014 through 2016 amounts to a punishment against the
Plaintiffs for failure to claim a right, because no other likewise situated taxpayer who failed
to apply for exemptions to which they are entitled would be charged a penalty. The “claw-
back” is limited to the assessment of the property at 100% market value.
64. Since the Plaintiffs came to the property appraiser on August 29, 2013 to apply for
the exemptions in time for tax year 2014, there can be no Penalty and Interest including for
tax years 2013 through 2016 because it is at best an oversight by the Appraiser. See Fla.
Stat. 196.161(b) (“if a homestead exemption is improperly granted as a result of a clerical
mistake or an omission by the property appraiser, the person improperly receiving the
exemption shall not be assessed penalty and interest.”)
WHEREFORE, Plaintiffs demand that this Court enter an order cancelling the
application of penalties and interest accruing from the date the tax is due to the date of the
Liens for tax years 2018 through 2016 regardless of whether the Exemptions are
reinstated; order the refund of all overpayments; awarding Plaintiffs their costs incurred in
bringing this action pursuant to section 194.192, Florida; and a declaration that the
Plaintiffs are the prevailing party; and any other remedy the court deems just and proper..
Page 11 of 13COUNT III - Removal of 2016 Recapture Tax, Interest and Penalties and
Overassessment for Tax Year 2017
65. Plaintiffs reassert and reaffirms the allegations of paragraphs 1 through 35 and as if
fully set forth herein, and further states:
66. Section 196.161, Florida Statutes allows the Property Appraiser to file a tax lien
against property of a taxpayer who was granted Exemption to which they were not entitled
for any year or years within the prior 10 years, to recapture said taxes, and to assess
penalties and interest thereon.
67. Section 193.1554(3), Florida Statutes provides, “Beginning in the year following the
year the non-homestead residential property becomes eligible for assessment pursuant to
this section, the property shall be reassessed annually on January 1. Any change resulting
from such reassessment may not exceed ten (10) percent of the assessed value of the
property for the prior year.
68. Assuming arguendo that the Defendants are correct that the Plaintiffs were not
entitled to homestead on the subject property for tax years 2014 through 2016, a position
which the Plaintiffs disputes and herein contests, the Defendants have not complied with
Fla. Stat. 198.1554(8) in determining the amount of the recapture tax for tax year 2016
because the Property Appraiser’s 2016 assessed value of a purported non-homestead
residential property exceed the statutory maximum permissible under Fla. Stat.
198.1554(8). This violation of Fla. Stat. § 193.1554) permeated and continued into the
assessed value for tax year 2017 because the 2016 assessed value was also used in 2017.
69. The Plaintiffs held an informal meeting with the property appraiser and apprised
the PA’s office that it’s assessed value for 2016 violated Florida law. The Property
Appraiser has refused to correct the issue, thus the overassessment in tax year 2017 is the
direct consequence of said refusal to comply with Fla. Stat. 198.1554(8) in tax year 2016.
Page 12 of 13WHEREFORE, Plaintiffs demand that this Court enter an order cancelling the Lien
for tax year 2016, the accrual of interest and the application of penalties regardless of
whether the Exemptions are reinstated; order the refund of all overpayments; awarding
Plaintiffs their costs incurred in bringing this action pursuant to section 194.192, Florida;
and a declaration that the Plaintiffs are the prevailing party; and any other remedy the
court deems just and proper.
Respectfully submitted this 17th day of April, 2018,
André Gibson, Chartered
/s/ André A, Gibson
André A. Gibson
Attorney for Plaintiffs, Raul Mejia and Virginia Lopez.
Florida Bar Number: 0635529
45 NE 67th Street,
North Miami Beach, FL 33162
Telephone: (3805) 652-4900
Fax: (305) 808-3495
E-Mail: AAGibson@Gibsontaxlaw.com
Secondary E-Mail: Efile@Gibsontaxlaw.com
Page 13 of 13EXHIBIT A
45 NE 167™ STREET, NORTH MIAMI BEACH, FL 33162
TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495
AAGibson@Gibsontaxlaw.comMIAMI-DADE COUNTY
PROPERTY APPRAISER
INVESTIGATION UNIT
PEDRO J. GARCIA
PROPERTY APPRAISER
CERTIFIED MAIL OTICE OF INTENT TO LIEN
RETURN RECEIPT REQUESTED
7013 2250 0OOE 3713 0573 December 5, 2016
RAUL MEJIA
VIRGINIA LOPEZ JTRS
201.178 DR #531
MIAMI, FL 33460-2898
RE: Violation Property: 204 178 DR 534 FOLIO: 33-2211-039-1220
Dear Property Owners:
The Miami-Dade County Property Appraiser’s Office reviewed the ad valorem property tax benefit(s) for the
above-captioned property and determined that the owner(s) of record was/were not entitled to the
Homestead Exemption. In accordance with sec. 196.161, Horida Statutes, enclosed is the Notice of Tax
Lien for Homestead Exemption and/or Limitation Exclusion (DR-453) reflecting applicable tax years, value
exempted, taxes exempted, and penalties and interest.
The Notice of Tax Lien for Homestead Exemption and/or Limitation Exclusion (DR-453) will be recorded with
the Clerk of the Circuit Court on or about January 5, 2017 as required by sec. 196.161, Florida Statutes. The
purpose of this lien is to recover the ad valorem taxes lost when the property received those benefit(s) to
which it was not entitled.
In lieu of recordation of the lien, you may pay the taxes and penalties and interest {if applicable) in the
amount of $23,977.68, Payment must be in the form of a cashier's check or money order made payable to
the “Miami-Dade County Tax Collector” and mailed to the Tax Collector's Office, 200 NW 2nd Avenue,
Miami, Florida 33128. Please note, if your lien contains penalties and interest, the amount specified in this
Notice will be subject to change beginning in 30 days. For questions regarding payments or payment
arrangements, please contact the Tax Collector's Office at 305-270-4916.
if you would like to discuss the Miami-Dade County Property Appraiser’s Office determination of non-
entitlement of benefits, please contact Mr. Julio Guas at 305-375-4237 or 305-375-3402. You may also
email the Investigations Section at fnvcustserv@ miamidade.gov.
Sincerely,
ee
o>
Ernesto Alonso CFE
Investigations Supervisor
Office of the Property Appraiser
HENS IST LIEAE 710 + MIAME, FLORIDA © 33128
PHOME: 305-375-602 © FAX: 305-375-1912
WEB SITE: WWW. MIAMIDADE.GOV/P A,Va: NOTICE OF TAX LIEN or4s3
5 FOR EXEMPTIONS AND Rule-121 te ode
H ASSESSMENT LIMITATIONS ene oi
FLORIDA Miami-Dade County, Florida
RAUL MEJIA, VIRGINIA LOPEZ JTRS (taxpayer) has received exemption(s)
and/or assessment limitation{s) totaling $42,743.48 for 5 years. The property
appraiser has discovered that the taxpayer was net legally entitled to receive the
exemption(s) and/or assessment limitation because:
RENTAL OF HOMESTEAD,
Sections 193,155(10), 193.1554(10), 193.1558(10), 193.504(9), 196.011 (9),
196.075(9), 196.161{1} and 196.183, F.S., require a lien on the property to
recover unpaid taxes. The property appraiser will recover from the taxpayer faxes
due, 2 50 percent penalty and 15 percent interest for any year or years
within the fast ten years in which the taxpayer was not entitled to, but was
granted, a tax exemption or assessment limitation.
When this document is recorded, it becomes a lien on the real property addressed
and legally owned by the taxpayer in Florida,
FOR OFFICIAL USE ONLY
Faxpayer RAUL MENA, VIRGINIA LOPEZ sTRS Parcel 1D 34-2211-039-1220 / Case #13809
name
Address ‘201178 DR53% Legal LE CARTIER CONDO
Sunny fsies Beach, 33160-2875 description UNIT 531,
UNDIV .61496%
Column 1 Column 2 Column 3 Column 4 Column 5 — Column 6
‘Tax Year/ Date tax due Reason for Lien Taxes Due Penalty Interest TOTAL [3+4«5)
2004 / 44/1/2011 RENTAL OF HOMESTEAD 2,098.53 1,049.27 “STC *sTC
2012 / 11/1/2042 RENTAL OF HOMESTEAD 2,028.96 1,012.48, *STC *sTC
2013 / 11/1/2023 RENTAL OF HOMESTEAD 2,695.54 1,347.78 *STC +sTC
nota / 11/1/2024 RENTAL OF HOMESTEAD 2,998.48 2,499.25 +STC +sTe
2018 / 11/1/2025 RENTAL OF HOMESTEAD 2,925.97 1,462.99 *sTC STC
Tax Gollector: The 50 percent penalty is calculated individually on each annual Total for Column 6 (subtotal) *stc
exemption or assessment limitation. Interest is based on the taxes exempted or excluded
each year from the date the taxes become due for each assessment until the lien is Added fees: Property Appraiser N/A
satisfied. and costs
The tax collector must collect any fees and costs which the property appraiser or the tax paid by: Tax Collecter 10.00
collector has incurred in filing and collecting this lien.
TOTAL DUE *STC
“STC See Tax Collector
| certify that | have read this notice of tax lien and the facts in it are true. If prepared by someone other than the property appraiser, this
declaration is based on ail information of which he or she has knowledge.
Deputy Property Appraiser.
Signature Title Date
Payment must include all unpaid taxes, interest, penalties, fees, and costs, or the lien will not be satisfied.MIAMI-DADE COUNTY
PROPERTY APPRAISER
INVESTIGATION UNIT
PEDRO J. GARCIA
PROPERTY APPRAISER
December 5, 2016
RAUL MERA
VIRGINIA LOPEZ JTRS
201 178 DR #531
MIAMI, FL 33460-2898
Property Address: 201 178 DR 531
Folio: 31-2211-039-1220
Dear RAUL MEJIA:
Pursuant to Section 196.161, Florida Statutes, you were not entitled to the exemption received on the
above referenced property for 2016. Therefore, to avoid a lien including penalties and interest from
being filed, the Office of the Property Appraiser requires your signature below to remove the
exemption and applicable assessment limitations.
If you have any questions regarding this matter, you may contact Mr. Julio Guas at 305-375-4237 or
305-375-3402, or via email at Invcustsen@miamidade gov.
Sincerely,
en
Co >
Ernesto Alonso CFE
Investigations Supervisor
Office of the Property Appraiser
| hereby authorize the Office of the Property Appraiser to remove the Homestead Exemption at the
above referenced address for 2016.
NAME
SIGNATURE DATEEXHIBIT B
45 NE 167™ STREET, NORTH MIAMI BEACH, FL 33162
TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495
AAGibson@Gibsontaxlaw.comMIAMI-DADE COUNTY
PROPERTY APPRAISER
INVESTIGATION UNIT
PEDRO J. GARCIA
PROPERTY APPRAISER
CERTIFIED MAIL NOTICE OF INTENT TO LIEN
RETURN RECEIPT REQUESTED
7OE7 1070 0000 0395 9089
July 3, 2017
RAUL MEJIA
VIRGINIA LOPEZ
201 178 DR #531
MIAMI, FL 33160-2898
RE: Violation Property: 201 178 DR 531 FOLIO: 34-2211-039-1220
Dear Property Owner:
The Miami-Dade County Property Appraiser’s Office reviewed the ad valorem property tax benefit(s} for the
above-captioned property and determined that the owner(s) of record was/were not entitled to the
Homestead Exemption. In accordance with sec. 196.011 and 196.161, Florida Statutes, enclosed is the
Notice of Tax Lien for Homestead Exemption and/or Limitation Exclusion (DR-453) reflecting applicable tax
years, value exempted, taxes exempted, and penalties and interest.
The Notice of Tax Lien for Homestead Exemption and/or Limitation Exclusion (DR-453) will be recorded with
the Clerk of the Circuit Court on or about August 1, 2047 as required by sec. 196.011 and 196.161, Florida
Statutes. The purpose of this Jien is to recover the ad valorem taxes fost when the property received those
benefit{s} to which it was not entitled.
in lieu of recordation of the lien, you may pay the taxes and penalties and interest (if applicable) in the
amount of $5,168.75. Payment must be in the form of a cashier's check or money order made payable to
the “Miami-Dade County Tax Collector” and mailed to the Tax Collector’s Office, 200 NW 2nd Avenue,
Miami, Florida 33128. Please note, if your lien contains penalties and interest, the amount specified in this
Notice will be subject to change beginning in 30 days. For questions regarding payments or payment
arrangements, please contact the Tax Collector's Office at 305-270-4916.
If you would like to discuss the Miami-Dade County Property Appraiser's Office determination of non-
entitlement of benefits, please contact Mr. Julio Guas at 305-375-4237 or 305-375-3402. You may also
email the investigations Section at invcustserv@miamidade.gov.
Ernesto Alonso CFE
investigations Supervisor
Office of the Property Appraiser: NOTICE OF TAX LIEN DR-453
: FOR EXEMPTIONS AND aye ot 048
! ASSESSMENT LIMITATIONS ends
FLORIDA Miami-Dade County, Florida
RAUL MEJIA, VIRGINIA LOPEZ JTRS (taxpayer) has received exemption(s)
and/or assessment linitation(s} totaling $3,364.79 for 1 year. The property
appraiser has discovered that the taxpayer was not legally entitled to receive the
exemption(s) and/or assessment limitation because:
RENTAL OF HOMESTEAD.
Sections 193.155(10), 193.1554(10), 193.1555(40), 193.504(9), 196.041(9),
196.075(9), 196.161 (1) and 196.183, F.S., require a lien on the property to
recover unpaid taxes. The property appraiser will recover from the taxpayer taxes.
due, a §0 percent penalty and 15 percent interest far any year or years
within the last ten years in which the taxpayer was not entitled to, but was.
granted, a tax exemption or assessment limitation.
When this document is recorded, it becomes a tien on the real property addressed
and legally owned by the taxpayer in Florida.
FOR OFFICIAL USE ONLY.
Column 6
TOTAL (34445)
“STC
+536
N/A
10.00
Taxpayer. RAUL MEJIA, VIRGINIA LOPEZ JTRS Parcel ID 34-2211-039-1220 / Case # 1474
name
Address 202178 0R 53 Legal LE CARTIER CONGO
Sunny isles Beach, 33160-2875 description UNIT 534,
UNDIV .64496% INT IN COMMON ELEMENTS
Column 1 Column 2 Column 3 Column 4 Column 5
Tax Year/ Date tax due Reason for tien Taxes Due Penalty interest
2016 / 11/1/2016 RENTAL OF HOMESTEAD 3,368.79 4,680.90 *sTC
Tax Collector: The 50 percent penalty is calculated individually on each annual Total for Colurmn 6 (subtotal)
exemption or assessment limitation. Interest is based on the taxes exempted or excluded
each year from the date the taxes become due for each assessment until the lien is Added fees Properly Appraiser
satisfied. and costs
The tax collector must collect any faes and costs which the property appraiser or the tax paid by. Tax Collector
collector has incurred in fifing and collecting this lien.
TOTAL DUE
“STC See Tax Collector
*sTC
| certify that | have read this notice of tax lien and the facts in it are true. If prepared by someone other than the property appraiser, this
declaration is based on all information of which he or she has knowledge.
Deputy Property Appraiser
Signature Title Date
Payment must include all unpaid taxes, interest, penalties, fees, and costs, or the lien will not be satisfied.EXHIBIT C
45 NE 167™ STREET, NORTH MIAMI BEACH, FL 33162
TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495
AAGibson@Gibsontaxlaw.comMIAMI-DADE COUNTY
PROPERTY APPRAISER
INVESTIGATIONS UNIT
PEDRO J. GARCIA
PROPERTY APPRAISER
August 18, 2017
RAUL MEJIA
VIRGINIA LOPEZ JTRS
201 178 DR #531
MIAMI, FL 33160-2898
RE: | ADDRESS: 201 178 DR 531
FOLIO: 31-2211-039-1220
LIEN CASE: ~ 13809
Dear Property Owners:
The above referenced property has been reviewed by the Miami-Dade County Property
Appraiser’s Office. After reviewing new evidence relevant to the case, it has been determined
that the new lien amount is $16,030.09. The original lien amount was $23,977.68. This letter is
intended to notify you of this change. In accordance with Florida Statute 196.161, the notice of
tax lien was recorded with the Clerk of The Circuit Court. Upon full payment of this amount, a
satisfaction of lien will be recorded by the Tax Collector’s Office.
If you have any questions regarding payment arrangements, please contact the Tax Collector’s
Office. Payment must be in the form of a cashier's check or money order made payable to the
“Miami-Dade County Tax Collector” and mailed to the Tax Collector’s Office, 200 NW 2nd
Avenue, Miami, Florida 33128. You may call the Tax Collector’s Office at (305) 270-4916.
If you need to discuss the Property Appraiser’s decision with respect to your property, please
call Mr. Julio Guas at (305) 375-4237 or (305) 375-3402.
Sincerely,
CL
Ernesto Alonso CFE
Investigations Supervisor
Office of the Property Appraiser
111 NW 187 STREET, SUITE 710 * MIAMI, FLORIDA + 33128
PHONE: 305-375-3402 * FAX: 305-375-1912
WEB SITE: WWW.MIAMIDADE.GOV/PAEXHIBIT D
45 NE 167™ STREET, NORTH MIAMI BEACH, FL 33162
TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495
AAGibson@Gibsontaxlaw.comMIAMI-DADE COUNTY
PROPERTY APPRAISER
INVESTIGATIONS UNIT
PEDRO J. GARCIA
PROPERTY APPRAISER
August 18, 2017
RAUL MEJIA
VIRGINIA LOPEZ JTRS
201 178 DR #531
MIAMI, FL 33160-2898
RE: ADDRESS: 201 178._DR 531
FOLIO: 31-2211-039-1220
LIEN CASE: 14771
Dear Property Owners:
The above referenced property has been reviewed by the Miami-Dade County Property
Appraiser’s Office. After reviewing new evidence relevant to the case, it has been determined
that the new lien amount is $5,104.11. The original lien amount was $5,168.75. This letter is
intended to notify you of this change. In accordance with Florida Statute 196.161, the notice of
tax lien was recorded with the Clerk of The Circuit Court. Upon full payment of this amount, a
satisfaction of lien will be recorded by the Tax Collector's Office.
If you have any questions regarding payment arrangements, please contact the Tax Collector's
Office. Payment must be in the form of a cashier's check or money order made payable to the
“Miami-Dade County Tax Collector” and mailed to the Tax Collector’s Office, 200 NW ana
Avenue, Miami, Florida 33128. You may call the Tax Collector’s Office at (305) 270-4916.
If you need to discuss the Property Appraiser’s decision with respect to your property, please
call Mr. Julio Guas at (305) 375-4237 or (305) 375-3402.
Sincerely,
C. — >
Ernesto Alonso CFE
Investigations Supervisor
Office of the Property Appraiser
111 NW 18T STREET, SUITE 710 + MIAMI, FLORIDA + 33128
PHONE: 305-375-3402 + FAX: 305-375-1912
WEB SITE: WWW,.MIAMIDADE.GOV/PAEXHIBIT E
45 NE 167™ STREET, NORTH MIAMI BEACH, FL 33162
TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495
AAGibson@Gibsontaxlaw.comANDRE GIBSON, CHARTERED
TAX & BUSINESS ATTORNEYS
ANDRE A. GIBSON
LICENSED IN
FLORIDA AND WISCONSIN
MeMBER OF THE UNiTeD States SUPREME Court BAR
LL.M. IN INTERNATIONAL TAXATION
August 30, 2017
VIA FEDEX: 7701-5139-8474
Miami-Dade Tax Collector
200 NW 2™ Avenue
Miami, FL 33128
Re: Tax Payment Under Protest: 31-2211-039-1220-HX-2013
Dear Tax Collector:
Attached hereto is my client’s payment for the 2013 tax year Homestead Penalty levied against
the captioned property. This payment is being made under protest as to the penalties and interest
charged on the recapture tax levy. Please note that legal action will be forthcoming on the
following basis:
1. Seeking a full refund of the interest and penalties charged in the recapture tax for 2013,
2. Challenging the denial of the homestead exemptions for 2014 through 2016 with the
interest and penalties charged, and;
3. In the alternative:
a. contesting the lack of legal basis to charge penalties and interest; and
b._ the calculations of the basis for the levy of Homestead Penalty Tax
Please process the attached check for the specified tax for tax year 2013. Should you have any
questions, please contact me directly.
Andre A. Gibson
Attorney for Virginia Lopez and Raul Mejia
Enclosure:
1, Attorney’s Trust Account Check No. 2874
Ce: Ely Gonzalez, Staff Attorney, Miami-Dade County Property Appraiser via email only
Page 1 of 4
45 NE 167" STREET, NORTH MIAMI BEACH, FL 33162
TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495
‘AAGibson@Gibsontaxlaw.comBip revrirtoonenesnaieasins Det ti Ny
2874
METH FR
ANDRE GIBSON, CHARTERED wrsbayne pieagctny COMER THR?
CUENT TRUST ACCOUNT aa ecaRE a
NbW TN Mane BEACH, PLS3 168 eeeenaters SOROV?
PE 305-682-4800
Ke ne Miami-Dade Tax Collector ff 75 A28. 78
Five Thousand Four Hundiéd Twenty-Four and 78/400" eetvewntestnervenntesconssevanenccoresventatscreeseeniweess Gy yp
Miami-Dade Tax Collector
200 NW 2 Avenue
Miami, FL A326
Under Protest 31-221 1-039-1220-HX-2013
“0028740 1: i 39°
ANDRE GIBSON, CHARTERED/CLIENT TRUST ACCOUNT
BT4
Miami-Dade Tex Collector BMVZOTT 2
Under Protest 34-221 1-O38-1280-HX-2013 SA24,78
Client Trust Accounts Under Protest: 34-2211-030-1220-HX-2013 5424.78
AMORE GIBSON, CHARTERED/CLIENT TRUST ACCOUNT 2874
Miam!-Dede Tax Collector BIOROT?
Under Protest: 34-221 1-039-1220-HX-2013 5424.78
Ghent Trust Aecounts Under Protest: 31-2211-038-1220-HX-2013 5,434.78
a ce aicate public_user 08/30/2017
2013 Homestead Penalty
Wn WN | | WM | PTET REP
Bu2211-090-1220-HX wor st2/e27T1O591220HX+20135% if Received By Please Pay
201 178 DR 531
PROPERTY ADDRESS Make checks payable to: Miami-Dade Tax Collector Aug 31, 2017 $5,424.78
(in U.S, funds drawn on U.S. banks)
iia-Dade Tex Colect | _Sep 30,2017 $5,458.48 __|
LEGAL DESCRIPTION. a
tEGes coneo Miami-Dade Tax Collector Sep 30,2017 $5,458.48
ONT 581 ose (in U.S. funds drawn on U.S. banks)
INT IN COMMON ELEMENTS Amount due May be Subject to Change Without Notice Oct 31, 2017 $5,492.18
RAUL MEJIA
VIRGINIA LOPEZ JTRS
201 178 DR #531
MIAMI, FL 33160-2898
9300000000000000031221103912e0HxX2013000002b95540000000000038/30/2017 FedEx Ship Manager - Print Your Label(s)
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After printing this label:
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41EXHIBIT F
45 NE 167™ STREET, NORTH MIAMI BEACH, FL 33162
TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495
AAGibson@Gibsontaxlaw.comANDRE GIBSON, CHARTERED
TAX & BUSINESS ATTORNEYS
ANDRE A. GIBSON
LiceNseDIN
FLoriDA AND WiscoNs N
Memeer of THE UNITED States Supreme Court BAR
LLM. IN INTERNATIONAL TAXATION
October 11, 2017
VIA FEDEX: 770470729056
Miami-Dade Tax Collector
200 NW 2™ Avenue
Miami, FL 33128
Re: Tax Payment Under Protest: 31-2211-039-1220-HX-2014-2016
Dear Tax Collector:
Please accept this letter as a correction to the letter related to this account dated October 9, 2017. (See
attached). The asterisks herein denote changes. Attached hereto is my client’s good-faith payment for the
recapture taxes and the relevant years. These payments are being made under protest as to the amount of
the recapture tax levy. It is the taxpayer’s position that no interest and penalties are due for the applicable
tax years, thus only the recapture tax levy for the respective years are paid:
1. Statutory Recapture Tax for Tax year 2014 $2,998.49
2. Statutory Recapture Tax for Tax year 2015 $2,925.97
3. Statutory Recapture Tax for Tax year 2016* $3,192.91
Please note that legal action will be forthcoming on the following basis:
1. Seeking a refund of the excess taxes,
2. Challenging the denial of the homestead exemptions for 2014 through 2016 with the interest and
penalties charged, and:
3. In the alternative:
a. contesting the lack of legal basis to charge penalties and interest; and
b. the calculations of the basis for the levy of Homestead Penalty Tax
Please process the attached checks for the specified tax for tax years 2014 — 2016*. Should you have any
questions, please contact me directly
Respectfully,
he
Andre A. Gibson
Attomey for Virginia Lopez and Raul Mejia
Enclosure
1. Copies of Check No. 2875 $2998.49; No. 2976 $2925.97; and No. 2877 $2,925.97
Ce: Ely Gonzalez, Staff Attorney, Miami-Dade County Property Appraiser via email only
Page 1 of 4
45 NE 167™ STREET, NORTH MIAMI BEACH, FL 33162
TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495
AAGibson@Gibsontaxlaw.comANDRE GIBSON, CHARTERED
TAX & BUSINESS ATTORNEYS
ANDRE A. GIBSON
LiceNseDIN
FLoriDA AND WiscoNs N
Memeer of THE UNITED States Supreme Court BAR
LLM. IN INTERNATIONAL TAXATION
October 9, 2017
VIA FEDEX: 7704-5059-5391
Miami-Dade Tax Collector
200 NW 2"! Avenue
Miami, FL 33128
Re: Tax Payment Under Protest: 31-2211-039-1220-HX-2013
Dear Tax Collector:
Attached hereto is my client’s good-faith payment for the recapture taxes and the relevant years.
These payments are being made under protest as to the amount of the recapture tax levy. It is the
taxpayer’s position that no interest and penalties are due for the applicable tax years, thus only
the recapture tax levy for the respective year paid.
1. Statutory Recapture Tax for Tax year 2014 $2,998.49
2. Statutory Recapture Tax for Tax year 2015 $2,925.97
3. Statutory Recapture Tax for Tax year 2014 $3,192.91
Please note that legal action will be forthcoming on the following basis:
1. Seeking a refund of the excess taxes,
2. Challenging the denial of the homestead exemptions for 2014 through 2016 with the
interest and penalties charged, and;
3. In the alternative
a. contesting the lack of legal basis to charge penalties and interest; and
b. the calculations of the basis for the levy of Homestead Penalty Tax
Please process the attached check for the specified tax for tax year 2013. Should you have any
questions, please contact me directly
Respectfully,
¢
Andre A. Gibson
Attorney for Virginia Lopez and Raul Mejia
Enclosure:
1. Trust Account Check No. 2875 $2998.49; No. 2976 $2925.97; and No. 2877 $2,925.97
Cc: Ely Gonzalez, Staff Attorney, Miami-Dade County Property Appraiser via email only
Page 1 of 4
‘45 NE 167™ STREET, NORTH MIAMI BEACH, FL 33162
TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495
‘AAGibson@Gibsontaxlaw.com2014 Homestead Penalty
31-2211-039-1220-HX
FOLIO NUMBER
201 178 DR_531
PROPERTY ADDRESS
LEGAL DESCRIPTION.
LE CARTIER CONDO.
UNIT 531
UNDIV .64496%
NT IN COMMON ELEMENTS
RAUL MEJIA
201 178 DR #531
MIAMI, FL 33160-2898
aot 31722711039 72208H
Make checks payable to: Miami-Dade Tax Collector
(in U.S. funds drawn on U.S. banks)
Make checks payable to:
Miami-Dade Tax Collector
(in U.S. funds drawn on U.S. banks)
x+2074
Amount due May be Subject to Change Without Notice
icate public_user 10/09/2017
PAY ONLY ONE AMOUNT
If Received By Please Pay
Oct 31, 2017 $5,659.54
Nov 30, 2017 $5,697.02
Dec 31, 2017 $5,734.50
90000000000000003122110391220HxX20140000029944 30000000000080 amen 2875
ANDRE GIBSON, CHARTERED Piccoeugnenecitueiennetry
CLENT TRUST ACCOUNT Take GoEANKe Bev
418 NW 163TH ST. STE. 26% ORTH MARE BEACH, 1, €x56)
PORTH RUBE BE SSH, FL OS 168. RS RERZOTE qm9r0077
PH 2OS-BE2-4900
ph Ber
Bee, @f Miami-Dade Tax Gallector 572.808.29
Twn Thousand Nine Hundred Ninety-Eight and 86/4 00*nesenrenscnscneeereerternenenerennentessstensemnrennenennns
Miami-Dade Tax Callsctor
200 NW 2 Averuse
Miami, FL 33128
| % Unster Profest! 31-221 1-4039-1220-HX-2014
002875
ANDRE GIBSON, CHARTERED/CLIENT TRUST ACCOUNT
. 2875
Miami-Dade Tax Callector OAWZO1?
Under Protect 31-2211-038-4220-HX-2014 2,998.49
Cent Trust Acoounts Under Protest 34-224 14039-4220-HX-2014 ZAR AQ
ANDRE GIBSON, CHARTERED/CLIENT TRUST ACCOUNT 2875
Miami-Dade Tax Collector WOGRO?
Uneer Profest 31-22 11-038-1220-HX-2014 2,988.48
Glient Trust Accounts Uncler Protest 31-22 71-099-1220-HX-2074 2,098.48
R HARE ee2015 Homestead Penalty
31-2211-039-1220-HX
FOLIO NUMBER
201 178 DR 531
PROPERTY ADDRESS
LEGAL DESCRIPTION.
LE CARTIER CONDO.
UNIT 531
UNDIV .64496%
NT IN COMMON ELEMENTS
RAUL MEJIA
VIRGINIA LOPEZ JTRS
201 178 DR #531
MIAMI, FL 33160-2898
aot 31722711039 72208H
Make checks payable to: Miami-Dade Tax Collector
(in U.S. funds drawn on U.S. banks)
Make checks payable to:
Miami-Dade Tax Collector
(in U.S. funds drawn on U.S. banks)
Amount due May be Subject to Change Without Notice
x+2015%
‘Additional Prior Year Property
Taxes are Owed and Not
Included in this Bill
icate public_user 10/09/2017
PAY ONLY ONE AMOUNT
If Received By Please Pay
Oct 31, 2017 $5,093.88
Nov 30, 2017 $5,130.46
Dec 31, 2017 $5,167.02
90000000000000003122110391220HxX201500000292597000000010009Cy £5 Sos mainonn naoina Seoeense,
2876
ANDRE GIBSON. CHARTERED SSnaINE FNADEIAL SENTER TPR?
) CLIENT TRUST ACCOUNT 19285 SGAYNE BLVD
318 MW TBPTH ST.; STE, Bi MOTH Mish) BBACH, ML BSISS
NORTH Nua BEACH, FL AGTBO BEBAUEED 1OGIO17
PH 308-682-8906
Liege BP os a
Kee f_ Miami-Dade Tax Collector 282897
Two Thousand Nine Hundred Twenty-Five and O7/100ttrstsservsrennsnssetrneneuntennttnnnenntnnananenny
Miami-Dade Tax Collector
200 NYY 2 Avenue
Miami, FL 33428
He
Under Protest: 31-22 11-039-4220-HS-2018
\ POO FR Poe
ANDAE GIBSON, CHARTERED/GLIENT TRUST ACCOURT 2876
Miami-Dade Tax Catlectar 4QARIZO4?
Under Protest: 34-2211-038-1220-HM-2018 2,985.97
Chant Trast Accounts Under Protest: $4-2211-036-1220-HX-2018 2825.87
ANDRE GIBSON, CHARTERED/CURRT TAUSY ACCOUNT 2876
Miami-Dade Tax Collector WYOROTT
Under Protest 34-22 44-4098-1220-HX-BO15 2,925.97
Client Trust Aorounts Under Protest: 34-2214-099-1220-HX-2018 2825.87
SEUEREEE = casee2016 Homestead Penalty
31-2211-039-1220-HX
FOLIO NUMBER
201 178 DR 531
PROPERTY ADDRESS
LEGAL DESCRIPTION.
LE CARTIER CONDO.
UNIT 531
UNDIV .64496%
NT IN COMMON ELEMENTS
RAUL MEJIA
VIRGINIA LOPEZ JTRS
201 178 DR #531
MIAMI, FL 33160-
Preview
Filing # 70815135 E-Filed 04/17/2018 11:59:48 AM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CIVIL ACTION RAUL MEJIA, and VIRGINIA LOPEZ Plaintiffs, CASE NO.: vs. DIVISION: PEDRO LOPEZ, as Property Appraiser of Miami Dade County Florida; LEON M. BIEGALSKI, as Executive Director of Florida Department of Revenue; MARCUS SAIZ DE LA MORA, as Tax Collector of Miami Dade County, Florida Defendants. / COMPLAINT FOR DECLARATORY RELIEF COMES NOW Plaintiffs, RAUL MEJIA (hereinafter, MEJIA) and VIRGINIA LOPEZ (hereinafter, LOPEZ), as Joint Tennant with Rights of survivorship, (hereinafter, “PLAINTIFFS”) and sues Defendants, PEDRO LOPEZ, as Property Appraiser of Miami Dade County Florida, (hereinafter “Appraiser”); LEON M. BIEGALSKI, as Executive Director of Florida Department of Revenue, (hereinafter, “DOR”); and MARCUS SAIZ DE LA MORA, as Tax Collector of Miami Dade County, Florida (hereinafter, “Collector’); the Collector, DOR, and Appraiser are hereinafter jointly referred to as Defendants, and allege: NATURE OF THE CASE 1. This is an action for a declaratory judgment and to challenge the removal and refusal to reinstate of a homestead and Senior Citizen exemptions (hereinafter, “Exemptions”) and imposition of retroactive tax liens on property in Miami-Dade County, Florida. PARTIES 2. Plaintiffs, MEJIA and LOPEZ, at all times relevant, are the owners of certain real Page 1 of 13property located at 201 178th Drive, unit 531, Sunny Isles, Florida 33160-2875, and identified as Parcel No. 31-2211-089-1220 (“Subject Property”), which was classified and assessed as owner-occupied residential property in tax year 2005 through 2016. 3. Appraiser is sued herein in his official capacity and is a necessary party to this action pursuant to section 194.181(2), Florida Statutes. 4. Collector is sued herein in his official capacity and is a necessary party to the action pursuant to section 194.181(3), Florida Statutes. 5. Defendant, LEON M. BIEGALSKI, is sued herein in his official capacity and is a necessarily party to the action pursuant to section 194.181(5), Florida Statutes. JURISDICTION 6. This Court has jurisdiction pursuant to Chapter 194, Florida Statutes, article V, sections 5 and 20 of the Florida Constitution, and section 86.011, Florida Statutes. VENUE 7. Venue is appropriate in this Court pursuant to Fla. Stat. Sections 47.011, and 47.021. GENERAL ALLEGATIONS 8. Plaintiffs jointly owned the Subject Property from 2005 through and including the present which consisted of a single residential or family unit and made it their permanent residence. 9. Except for tax year 2013, from 2005 through and including tax year 2017, the Plaintiffs have occupied and used the Subject. Property predominantly or exclusively as their homestead. 10. The Plaintiffs applied for and received a homestead exemption on the subject. in 2005 which was automatically renewed through 2012; however, on or about August 29, 2018, MEJIA visited the Property Appraiser’s office and informed them that the property Page 2 of 13was rented from April 2012 to April 2013 and sought to renew and reapply for the exemption to commence tax year 2014. 11. While at the property appraiser's office, MEJIA was informed that he may be eligible for a Senior Citizen Exemption. The agent assisted MEJIA with completing the forms. MEJIA had no intent to seek an exemption for 2013, however, the Agent completed the form as a late application for exemption. This was error. 12. On December 5, 2016, the Appraiser made a determination that the Plaintiffs “were not entitled to the Homestead Exemption” on the Subject Property and issued a Notice of Intent to Lien the subject property for tax years 2011 through 2015. See Exhibits A attached hereto 13. Upon the Plaintiffs contest of the determination and Notice of Intent to Lien for tax years 2011 through 2015, the Appraiser reversed its position with respect to tax years 2011 and 2012, but maintained their position with respect to tax years 2018 through 2015. See Exhibit C attached hereto 14, Again, on July 3, 2017, the Appraiser made a determination that the Subject Property and Plaintiffs “were not entitled to the Homestead Exemption” and issued a Notice of Intent to Lien the subject property for tax years 2016. See Exhibits B and D attached hereto 15. On information from the Appraiser, the specific basis for the removal of the exemptions for years 2013 through 2016 is as follows: a. For tax year 2013 the Appraiser states that based on a rental contract produced by the Plaintiff to the Appraiser, the property was not being used as a homestead. b. For tax years 2014 through 2016 the Appraiser states that the Plaintiffs failed to reapply for the exemptions which was removed in 2013; however, the DR-453 Page 3 of 13forms supplied by the Property Appraiser states that the exemptions were being denied and the retroactive tax levied as a result of “Rental of Homestead.” 16. The Plaintiffs do not contest the removal of the exemptions as it relates to tax year 2018 and as such has paid the Retroactive Tax; however, the Plaintiffs maintain that the levy of interest and penalties for tax year 2013 is not supported by law and the facts. See Exhibit E attached hereto 17. On or about August 29, 2013 when MEJIA visited the Appraiser’s office and applied for Senior Citizenship Exemptions pursuant to Fla. Stat. 196.075 in addition to notifying the Property Appraiser of the loss of 2013 exemption and seeking to apply for the 2014 homestead exemption. This Senior Citizen Exemption application was an_ initial application which necessarily accompanied and required that the Subject Property be declared the homestead. 18.The property appraiser granted retroactive benefits to the Senior Citizenship Exemption application for tax year 2013 and future years although MEJIA informed them of the loss of Homestead for 2013 and sought only 2014 forward. 19. As at April 17, 2018, the subject property was no longer under contract for rental and was being used as the Plaintiffs’ homestead which entitled them to exemptions for tax years 2014 through present. 20. The application for senior citizenship exemption on August 29, 2018, although late for tax year 2018, was timely received for tax year 2014. 21.The Plaintiffs own no other property on which to claim or receive a homestead exemption or Senior Citizen Exemption in the state of Florida or any other state. 22. The Plaintiffs have provided the Defendants with all documents to establish that the subject property is their homestead, yet the Appraiser maintains the same position that the subject property is being rented and that the taxpayers have failed to provide statutory Page 4 of 13evidence that the Subject Property is their permanent address. This position of the Property Appraiser is unsupported by the facts and law. 23. An actual case and controversy exists between the parties that may be adjudicated by this Court. 24.The Defendants have taken affirmative action against Plaintiffs by placing a lien against their property. 25. Plaintiffs have a reasonable apprehension that it will suffer irreparable injury if the Defendants does to release the lien against their property because interest continues to accrue and the property is in jeopardy of eventual say by the defendants to satisfy the liens. 26.The Defendants demanded that Plaintiffs pay the Liens (including interest and penalties) resulting from the removal of Exemptions, to which Exemptions the Plaintiffs are entitled. 27. Plaintiffs have a real and reasonable apprehension that if they should fail to pay the Lien they will be penalized by the Defendants and their Subject Property would be taken and used to satisfy said Lien. 28.The Declarations sought herein is necessary and appropriate under the circumstances in order that Plaintiffs may ascertain Exemptions to which they are entitled and the correct amount of recapture tax, penalties and interest, if any, permissible by law. 29. Pursuant to Fla. Stat. § 86.011 this Court has jurisdiction to declare the existence or nonexistence of any fact upon which the existence or nonexistence of an immunity, power, privilege, or right does or may depend, whether such immunity, power, privilege, or right now exists or will arise in the future. 30. Pursuant to Fla. Stat. § 86.051 allows the Court to render a declaratory judgment by way of anticipation with respect “to any act not yet done or any event which has not yet happened.” Page 5 of 1331, Pursuant to Fla. Stat. § 86.111 also permits “a speedy hearing of an action for declaratory judgment” and the Court “may advance it on the calendar.” 32. Pursuant to Fla. Stat. § 86.101 provides that this Court has jurisdiction to address the instant matter to settle and to afford relief from insecurity and uncertainty with respect to rights, status, and other equitable or legal relations. 33. The failure to stop the Defendant’s past and present course of conduct as set forth herein would be to endorse an injustice and loss of the plaintiffs property, and monies paid under protest so as to establish standing for this action. 34. Prior to instituting this action, the Plaintiffs: a. Paid under protest the entire recapture tax levy with interest and penalties for tax year 2013; See Exhibit E attached hereto b. Paid under protest the amount of the recapture tax for tax years 2014 through 2016 as good faith payment which exceeds the amount the recapture tax when the exemptions are reinstated and/or the amount of interest and penalties are removed; See Exhibit F attached hereto c. Paid the 2017 tax bill under protest. See Exhibit G attached hereto 35. All conditions precedent to filing this suit have been met. COUNT I - REMOVAL OF TAX LIEN (As to Tax Years 2014 through 2016) 36. Plaintiffs reassert and reaffirms the allegations of paragraphs 1 through 35 as if fully set forth herein, and further states: 37. On December 5, 2016 and July 3, 2017, the Appraiser sent the Plaintiffs a Notice of Intent to File Lien (hereinafter “Lien Notices”) notifying them that the homestead and senior citizenship exemptions on the Subject Property would be retroactively removed for the 2011-2015 and 2016 tax years respectively. Copies of the Liens are attached hereto as Page 6 of 13Exhibits A through D, H and I. 38. The Lien Notices stated that the reason for the removal of the Exemptions was due to rental of the homestead. See Exhibit A at 2, and Exhibit B at 2 39. Consistent with the Lien Notices, the Appraiser and Collector recorded the tax liens against the Subject Property. 40. Section 196.161, Florida Statutes allows the Property Appraiser to file a tax lien against property of a taxpayer who was granted Exemption to which they were not entitled for any year or years within the prior 10 years, to recapture said taxes, and to assess penalties thereon. Al. Under section 196.061 and consistent with section 196.198(8),(4), Florida Statutes, “In order for there to be entitlement to a homestead tax exemption, an individual must show ownership of the home, residence therein, and the making of such residence as the permanent home in good faith.” See AGO 2008-18, 2008 Fla. AG LEXIS 14. 42. The Plaintiffs have resided in the subject property as their permanent home since April 17, 2013. 43. The Plaintiffs applied for exemption in August 2013 with sufficient time to obtain the exemptions for tax years 2014 and subsequent years, thus the Plaintiffs were entitled to the Exemption on the Subject Property in the 2014 through 2016 tax years, pursuant to article VII, section 6 of the Florida Constitution and section 196.031, Florida Statutes. Thus, the Property Appraiser's retroactive removal of the homestead exemption and imposition of a tax lien was unlawful. 44. The Subject Property was being used as the Plaintiff's permanent residence for tax years 2014 through 2016, thus it is contrary to law to deny the Plaintiff's the Exemptions and to levy retroactive tax thereon. WHEREFORE, Plaintiffs request that this Court enter an order reinstating the Page 7 of 132014 through 2016 homestead and senior citizen exemptions on the subject property; cancelling the tax lien; order the refund of all overpayments, awarding Plaintiffs their costs incurred in bringing this action pursuant to section 194.192, Florida, and any other remedy the court deems just and proper. COUNT II - Removal of Tax Lien Interest and Penalties (As to Tax Years 2014-2016) 45, Plaintiffs reassert and reaffirms the allegations of paragraphs 1 through 35 as if fully set forth herein, and further states: 46. On December 5, 2016 and July 3, 2017, the Appraiser sent the Plaintiffs a Notice of Intent to File Lien (hereinafter “Lien Notices”) notifying them that the homestead and senior citizenship exemptions on the Subject Property would be retroactively removed for the 2011-2015 and 2016 tax years respectively. Copies of the Liens are attached hereto as Exhibits A through D, H and I. 47. Section 196.161, Florida Statutes allows the Property Appraiser to file a tax lien against property of a taxpayer who was granted Exemption to which they were not entitled for any year or years within the prior 10 years, to recapture said taxes, and to assess penalties and interest thereon. 48. Under section 196.061 and consistent with Fla. Stat. § 196.193(3),(4), “In order for there to be entitlement to a homestead tax exemption, an individual must show ownership of the home, residence therein, and the making of such residence as the permanent home in good faith. See AGO 2008-18, 2008 Fla. AG LEXIS 14. 49. The Subject Property was not being rented in tax years 2014 through 2016 and the plaintiffs resided therein as their permanent and primary residence. 50. In discussions with the Appraiser, the Appraiser’s position is that the Plaintiffs failed to apply for their Exemptions for the tax years subsequent to the 2013 tax year of the Page 8 of 13removal of the exemption; however, the notices indicate that the exemptions were removed due to rental of the homestead. The Appraiser’s position is that the Plaintiffs failed to reapply for their exemptions and is thus subject to a lien for penalties. 51. Even assuming arguendo that the Plaintiffs did not timely apply or failed to apply for Exemptions on the Subject Property for tax years 2014 through 2016, a position the plaintiffs dispute, there is no basis for the assessment of penalties in tax years 2014 through 2016 because the Plaintiffs were entitled to the exemption as a matter of law. Absent wrongdoing in obtaining an exemption, there is no basis in law to assess penalties and interest. Moreover, notwithstanding mere entitlement, the Plaintiffs did apply for the exemption in time for the 2014 tax year. 52. Since the Property was not being rented, the Plaintiffs were entitled to the Exemptions under Fla. Stat. §§ 196.161(b) and 196.011 because the property was not being used for a non-exempt purpose and the plaintiffs did not defraud the Defendants to obtain a benefit to which they were otherwise entitled. 53. Even if the Plaintiffs had failed to apply for Exemptions for tax years 2014, which they did not, the Plaintiffs were entitled to the exemptions, thus the recapture of a tax for failure to apply for Exemptions which the property appraiser granted is not a basis under Fla. Stat. § 196.161(1)() to assess penalties and interest. Had the Plaintiffs simply failed to apply for the Exemptions to which they are entitled, they would simply not the granted the exemptions, but no penalty or interest under Fla. Stat. § 196.161 can be levied for failure to make an application because there is no basis to establish a lack of entitlement. 54. The Plaintiffs were permanent residents of the state of Florida and resided in the Subject Property in tax years 2014 through 2016, as such there is no wrongdoing to denying them of entitlement to the homestead exemption, thus there can be no interest or penalty assessed under Fla. Stat. § 196.161. Page 9 of 1355. For interest and penalties to be assessed on a recapture tax pursuant to Fla. Stat. § 196.161, the Property owners must first be determined to be “a person who was not entitled to a homestead exemption [and] was granted a homestead exemption from ad valorem taxes.” 56. The triggering event for the levy of interest and penalties under Fla. Stat. § 196.161(1)(b) is a lack of entitlement; not whether an application for said exemptions to which the Plaintiffs are otherwise entitled, was filed. Thus, even assuming arguendo that the Plaintiffs had not applied for the exemptions after 2013, which is not the case, the plaintiffs were entitled to the exemptions because the use of the property dictated the “entitlement.” 57. Entitlement under the statute is a matter of actual entitlement to claim the exemption. See Mitchell v. Higgs, 61 So. 3d 1152, 1155 (Fla. 3 DCA 2011) (“The legislature has imposed a series of requirements for eligibility for the homestead tax exemption and a mechanism for recovering the tax savings (plus interest and a penalty) realized by a property owner not actually entitled to claim the exemption.”) 58. For the penalties to be levied, the Plaintiffs would necessarily have had to receive the homestead exemption unlawfully. See also, Fla. Stat. § 196.161(8) (Such lien when filed shall attach to any property which is identified in the notice of lien and is owned by the person who illegally or improperly received the homestead exemption.) 59. With respect to 2014 through 2016, where there is no rental of the homestead property, the levy of penalty is contrary to law because the Plaintiffs did not obtain the homestead exemption illegally. 60. Moreover, and consistent with the foregoing, Fla. Stat. § 196.161(1)(b) provides, “if a homestead exemption is improperly granted as a result of a clerical mistake or an omission by the property appraiser, the person improperly receiving the exemption shall Page 10 of 13not be assessed penalty and interest.” 61. Consistent with Fla. Stat. § 196.161(1)(b), Fla. Stat. Fla. Stat. § 196.161(8) requires that an improper receipt pf a homestead exemption would also result in a lien for the recapture tax, however, the improper receipt of the homestead is as defined in Fla. Stat. § 196.161(1)(b). 62. The Plaintiffs were actually entitled to claim the exemptions and in fact took steps to claim exemptions in August 2013 in time for the 2014 tax year. 63. Even assuming arguendo that the plaintiffs failed to apply for the exemption, the levy of penalties for tax year 2014 through 2016 amounts to a punishment against the Plaintiffs for failure to claim a right, because no other likewise situated taxpayer who failed to apply for exemptions to which they are entitled would be charged a penalty. The “claw- back” is limited to the assessment of the property at 100% market value. 64. Since the Plaintiffs came to the property appraiser on August 29, 2013 to apply for the exemptions in time for tax year 2014, there can be no Penalty and Interest including for tax years 2013 through 2016 because it is at best an oversight by the Appraiser. See Fla. Stat. 196.161(b) (“if a homestead exemption is improperly granted as a result of a clerical mistake or an omission by the property appraiser, the person improperly receiving the exemption shall not be assessed penalty and interest.”) WHEREFORE, Plaintiffs demand that this Court enter an order cancelling the application of penalties and interest accruing from the date the tax is due to the date of the Liens for tax years 2018 through 2016 regardless of whether the Exemptions are reinstated; order the refund of all overpayments; awarding Plaintiffs their costs incurred in bringing this action pursuant to section 194.192, Florida; and a declaration that the Plaintiffs are the prevailing party; and any other remedy the court deems just and proper.. Page 11 of 13COUNT III - Removal of 2016 Recapture Tax, Interest and Penalties and Overassessment for Tax Year 2017 65. Plaintiffs reassert and reaffirms the allegations of paragraphs 1 through 35 and as if fully set forth herein, and further states: 66. Section 196.161, Florida Statutes allows the Property Appraiser to file a tax lien against property of a taxpayer who was granted Exemption to which they were not entitled for any year or years within the prior 10 years, to recapture said taxes, and to assess penalties and interest thereon. 67. Section 193.1554(3), Florida Statutes provides, “Beginning in the year following the year the non-homestead residential property becomes eligible for assessment pursuant to this section, the property shall be reassessed annually on January 1. Any change resulting from such reassessment may not exceed ten (10) percent of the assessed value of the property for the prior year. 68. Assuming arguendo that the Defendants are correct that the Plaintiffs were not entitled to homestead on the subject property for tax years 2014 through 2016, a position which the Plaintiffs disputes and herein contests, the Defendants have not complied with Fla. Stat. 198.1554(8) in determining the amount of the recapture tax for tax year 2016 because the Property Appraiser’s 2016 assessed value of a purported non-homestead residential property exceed the statutory maximum permissible under Fla. Stat. 198.1554(8). This violation of Fla. Stat. § 193.1554) permeated and continued into the assessed value for tax year 2017 because the 2016 assessed value was also used in 2017. 69. The Plaintiffs held an informal meeting with the property appraiser and apprised the PA’s office that it’s assessed value for 2016 violated Florida law. The Property Appraiser has refused to correct the issue, thus the overassessment in tax year 2017 is the direct consequence of said refusal to comply with Fla. Stat. 198.1554(8) in tax year 2016. Page 12 of 13WHEREFORE, Plaintiffs demand that this Court enter an order cancelling the Lien for tax year 2016, the accrual of interest and the application of penalties regardless of whether the Exemptions are reinstated; order the refund of all overpayments; awarding Plaintiffs their costs incurred in bringing this action pursuant to section 194.192, Florida; and a declaration that the Plaintiffs are the prevailing party; and any other remedy the court deems just and proper. Respectfully submitted this 17th day of April, 2018, André Gibson, Chartered /s/ André A, Gibson André A. Gibson Attorney for Plaintiffs, Raul Mejia and Virginia Lopez. Florida Bar Number: 0635529 45 NE 67th Street, North Miami Beach, FL 33162 Telephone: (3805) 652-4900 Fax: (305) 808-3495 E-Mail: AAGibson@Gibsontaxlaw.com Secondary E-Mail: Efile@Gibsontaxlaw.com Page 13 of 13EXHIBIT A 45 NE 167™ STREET, NORTH MIAMI BEACH, FL 33162 TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495 AAGibson@Gibsontaxlaw.comMIAMI-DADE COUNTY PROPERTY APPRAISER INVESTIGATION UNIT PEDRO J. GARCIA PROPERTY APPRAISER CERTIFIED MAIL OTICE OF INTENT TO LIEN RETURN RECEIPT REQUESTED 7013 2250 0OOE 3713 0573 December 5, 2016 RAUL MEJIA VIRGINIA LOPEZ JTRS 201.178 DR #531 MIAMI, FL 33460-2898 RE: Violation Property: 204 178 DR 534 FOLIO: 33-2211-039-1220 Dear Property Owners: The Miami-Dade County Property Appraiser’s Office reviewed the ad valorem property tax benefit(s) for the above-captioned property and determined that the owner(s) of record was/were not entitled to the Homestead Exemption. In accordance with sec. 196.161, Horida Statutes, enclosed is the Notice of Tax Lien for Homestead Exemption and/or Limitation Exclusion (DR-453) reflecting applicable tax years, value exempted, taxes exempted, and penalties and interest. The Notice of Tax Lien for Homestead Exemption and/or Limitation Exclusion (DR-453) will be recorded with the Clerk of the Circuit Court on or about January 5, 2017 as required by sec. 196.161, Florida Statutes. The purpose of this lien is to recover the ad valorem taxes lost when the property received those benefit(s) to which it was not entitled. In lieu of recordation of the lien, you may pay the taxes and penalties and interest {if applicable) in the amount of $23,977.68, Payment must be in the form of a cashier's check or money order made payable to the “Miami-Dade County Tax Collector” and mailed to the Tax Collector's Office, 200 NW 2nd Avenue, Miami, Florida 33128. Please note, if your lien contains penalties and interest, the amount specified in this Notice will be subject to change beginning in 30 days. For questions regarding payments or payment arrangements, please contact the Tax Collector's Office at 305-270-4916. if you would like to discuss the Miami-Dade County Property Appraiser’s Office determination of non- entitlement of benefits, please contact Mr. Julio Guas at 305-375-4237 or 305-375-3402. You may also email the Investigations Section at fnvcustserv@ miamidade.gov. Sincerely, ee o> Ernesto Alonso CFE Investigations Supervisor Office of the Property Appraiser HENS IST LIEAE 710 + MIAME, FLORIDA © 33128 PHOME: 305-375-602 © FAX: 305-375-1912 WEB SITE: WWW. MIAMIDADE.GOV/P A,Va: NOTICE OF TAX LIEN or4s3 5 FOR EXEMPTIONS AND Rule-121 te ode H ASSESSMENT LIMITATIONS ene oi FLORIDA Miami-Dade County, Florida RAUL MEJIA, VIRGINIA LOPEZ JTRS (taxpayer) has received exemption(s) and/or assessment limitation{s) totaling $42,743.48 for 5 years. The property appraiser has discovered that the taxpayer was net legally entitled to receive the exemption(s) and/or assessment limitation because: RENTAL OF HOMESTEAD, Sections 193,155(10), 193.1554(10), 193.1558(10), 193.504(9), 196.011 (9), 196.075(9), 196.161{1} and 196.183, F.S., require a lien on the property to recover unpaid taxes. The property appraiser will recover from the taxpayer faxes due, 2 50 percent penalty and 15 percent interest for any year or years within the fast ten years in which the taxpayer was not entitled to, but was granted, a tax exemption or assessment limitation. When this document is recorded, it becomes a lien on the real property addressed and legally owned by the taxpayer in Florida, FOR OFFICIAL USE ONLY Faxpayer RAUL MENA, VIRGINIA LOPEZ sTRS Parcel 1D 34-2211-039-1220 / Case #13809 name Address ‘201178 DR53% Legal LE CARTIER CONDO Sunny fsies Beach, 33160-2875 description UNIT 531, UNDIV .61496% Column 1 Column 2 Column 3 Column 4 Column 5 — Column 6 ‘Tax Year/ Date tax due Reason for Lien Taxes Due Penalty Interest TOTAL [3+4«5) 2004 / 44/1/2011 RENTAL OF HOMESTEAD 2,098.53 1,049.27 “STC *sTC 2012 / 11/1/2042 RENTAL OF HOMESTEAD 2,028.96 1,012.48, *STC *sTC 2013 / 11/1/2023 RENTAL OF HOMESTEAD 2,695.54 1,347.78 *STC +sTC nota / 11/1/2024 RENTAL OF HOMESTEAD 2,998.48 2,499.25 +STC +sTe 2018 / 11/1/2025 RENTAL OF HOMESTEAD 2,925.97 1,462.99 *sTC STC Tax Gollector: The 50 percent penalty is calculated individually on each annual Total for Column 6 (subtotal) *stc exemption or assessment limitation. Interest is based on the taxes exempted or excluded each year from the date the taxes become due for each assessment until the lien is Added fees: Property Appraiser N/A satisfied. and costs The tax collector must collect any fees and costs which the property appraiser or the tax paid by: Tax Collecter 10.00 collector has incurred in filing and collecting this lien. TOTAL DUE *STC “STC See Tax Collector | certify that | have read this notice of tax lien and the facts in it are true. If prepared by someone other than the property appraiser, this declaration is based on ail information of which he or she has knowledge. Deputy Property Appraiser. Signature Title Date Payment must include all unpaid taxes, interest, penalties, fees, and costs, or the lien will not be satisfied.MIAMI-DADE COUNTY PROPERTY APPRAISER INVESTIGATION UNIT PEDRO J. GARCIA PROPERTY APPRAISER December 5, 2016 RAUL MERA VIRGINIA LOPEZ JTRS 201 178 DR #531 MIAMI, FL 33460-2898 Property Address: 201 178 DR 531 Folio: 31-2211-039-1220 Dear RAUL MEJIA: Pursuant to Section 196.161, Florida Statutes, you were not entitled to the exemption received on the above referenced property for 2016. Therefore, to avoid a lien including penalties and interest from being filed, the Office of the Property Appraiser requires your signature below to remove the exemption and applicable assessment limitations. If you have any questions regarding this matter, you may contact Mr. Julio Guas at 305-375-4237 or 305-375-3402, or via email at Invcustsen@miamidade gov. Sincerely, en Co > Ernesto Alonso CFE Investigations Supervisor Office of the Property Appraiser | hereby authorize the Office of the Property Appraiser to remove the Homestead Exemption at the above referenced address for 2016. NAME SIGNATURE DATEEXHIBIT B 45 NE 167™ STREET, NORTH MIAMI BEACH, FL 33162 TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495 AAGibson@Gibsontaxlaw.comMIAMI-DADE COUNTY PROPERTY APPRAISER INVESTIGATION UNIT PEDRO J. GARCIA PROPERTY APPRAISER CERTIFIED MAIL NOTICE OF INTENT TO LIEN RETURN RECEIPT REQUESTED 7OE7 1070 0000 0395 9089 July 3, 2017 RAUL MEJIA VIRGINIA LOPEZ 201 178 DR #531 MIAMI, FL 33160-2898 RE: Violation Property: 201 178 DR 531 FOLIO: 34-2211-039-1220 Dear Property Owner: The Miami-Dade County Property Appraiser’s Office reviewed the ad valorem property tax benefit(s} for the above-captioned property and determined that the owner(s) of record was/were not entitled to the Homestead Exemption. In accordance with sec. 196.011 and 196.161, Florida Statutes, enclosed is the Notice of Tax Lien for Homestead Exemption and/or Limitation Exclusion (DR-453) reflecting applicable tax years, value exempted, taxes exempted, and penalties and interest. The Notice of Tax Lien for Homestead Exemption and/or Limitation Exclusion (DR-453) will be recorded with the Clerk of the Circuit Court on or about August 1, 2047 as required by sec. 196.011 and 196.161, Florida Statutes. The purpose of this Jien is to recover the ad valorem taxes fost when the property received those benefit{s} to which it was not entitled. in lieu of recordation of the lien, you may pay the taxes and penalties and interest (if applicable) in the amount of $5,168.75. Payment must be in the form of a cashier's check or money order made payable to the “Miami-Dade County Tax Collector” and mailed to the Tax Collector’s Office, 200 NW 2nd Avenue, Miami, Florida 33128. Please note, if your lien contains penalties and interest, the amount specified in this Notice will be subject to change beginning in 30 days. For questions regarding payments or payment arrangements, please contact the Tax Collector's Office at 305-270-4916. If you would like to discuss the Miami-Dade County Property Appraiser's Office determination of non- entitlement of benefits, please contact Mr. Julio Guas at 305-375-4237 or 305-375-3402. You may also email the investigations Section at invcustserv@miamidade.gov. Ernesto Alonso CFE investigations Supervisor Office of the Property Appraiser: NOTICE OF TAX LIEN DR-453 : FOR EXEMPTIONS AND aye ot 048 ! ASSESSMENT LIMITATIONS ends FLORIDA Miami-Dade County, Florida RAUL MEJIA, VIRGINIA LOPEZ JTRS (taxpayer) has received exemption(s) and/or assessment linitation(s} totaling $3,364.79 for 1 year. The property appraiser has discovered that the taxpayer was not legally entitled to receive the exemption(s) and/or assessment limitation because: RENTAL OF HOMESTEAD. Sections 193.155(10), 193.1554(10), 193.1555(40), 193.504(9), 196.041(9), 196.075(9), 196.161 (1) and 196.183, F.S., require a lien on the property to recover unpaid taxes. The property appraiser will recover from the taxpayer taxes. due, a §0 percent penalty and 15 percent interest far any year or years within the last ten years in which the taxpayer was not entitled to, but was. granted, a tax exemption or assessment limitation. When this document is recorded, it becomes a tien on the real property addressed and legally owned by the taxpayer in Florida. FOR OFFICIAL USE ONLY. Column 6 TOTAL (34445) “STC +536 N/A 10.00 Taxpayer. RAUL MEJIA, VIRGINIA LOPEZ JTRS Parcel ID 34-2211-039-1220 / Case # 1474 name Address 202178 0R 53 Legal LE CARTIER CONGO Sunny isles Beach, 33160-2875 description UNIT 534, UNDIV .64496% INT IN COMMON ELEMENTS Column 1 Column 2 Column 3 Column 4 Column 5 Tax Year/ Date tax due Reason for tien Taxes Due Penalty interest 2016 / 11/1/2016 RENTAL OF HOMESTEAD 3,368.79 4,680.90 *sTC Tax Collector: The 50 percent penalty is calculated individually on each annual Total for Colurmn 6 (subtotal) exemption or assessment limitation. Interest is based on the taxes exempted or excluded each year from the date the taxes become due for each assessment until the lien is Added fees Properly Appraiser satisfied. and costs The tax collector must collect any faes and costs which the property appraiser or the tax paid by. Tax Collector collector has incurred in fifing and collecting this lien. TOTAL DUE “STC See Tax Collector *sTC | certify that | have read this notice of tax lien and the facts in it are true. If prepared by someone other than the property appraiser, this declaration is based on all information of which he or she has knowledge. Deputy Property Appraiser Signature Title Date Payment must include all unpaid taxes, interest, penalties, fees, and costs, or the lien will not be satisfied.EXHIBIT C 45 NE 167™ STREET, NORTH MIAMI BEACH, FL 33162 TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495 AAGibson@Gibsontaxlaw.comMIAMI-DADE COUNTY PROPERTY APPRAISER INVESTIGATIONS UNIT PEDRO J. GARCIA PROPERTY APPRAISER August 18, 2017 RAUL MEJIA VIRGINIA LOPEZ JTRS 201 178 DR #531 MIAMI, FL 33160-2898 RE: | ADDRESS: 201 178 DR 531 FOLIO: 31-2211-039-1220 LIEN CASE: ~ 13809 Dear Property Owners: The above referenced property has been reviewed by the Miami-Dade County Property Appraiser’s Office. After reviewing new evidence relevant to the case, it has been determined that the new lien amount is $16,030.09. The original lien amount was $23,977.68. This letter is intended to notify you of this change. In accordance with Florida Statute 196.161, the notice of tax lien was recorded with the Clerk of The Circuit Court. Upon full payment of this amount, a satisfaction of lien will be recorded by the Tax Collector’s Office. If you have any questions regarding payment arrangements, please contact the Tax Collector’s Office. Payment must be in the form of a cashier's check or money order made payable to the “Miami-Dade County Tax Collector” and mailed to the Tax Collector’s Office, 200 NW 2nd Avenue, Miami, Florida 33128. You may call the Tax Collector’s Office at (305) 270-4916. If you need to discuss the Property Appraiser’s decision with respect to your property, please call Mr. Julio Guas at (305) 375-4237 or (305) 375-3402. Sincerely, CL Ernesto Alonso CFE Investigations Supervisor Office of the Property Appraiser 111 NW 187 STREET, SUITE 710 * MIAMI, FLORIDA + 33128 PHONE: 305-375-3402 * FAX: 305-375-1912 WEB SITE: WWW.MIAMIDADE.GOV/PAEXHIBIT D 45 NE 167™ STREET, NORTH MIAMI BEACH, FL 33162 TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495 AAGibson@Gibsontaxlaw.comMIAMI-DADE COUNTY PROPERTY APPRAISER INVESTIGATIONS UNIT PEDRO J. GARCIA PROPERTY APPRAISER August 18, 2017 RAUL MEJIA VIRGINIA LOPEZ JTRS 201 178 DR #531 MIAMI, FL 33160-2898 RE: ADDRESS: 201 178._DR 531 FOLIO: 31-2211-039-1220 LIEN CASE: 14771 Dear Property Owners: The above referenced property has been reviewed by the Miami-Dade County Property Appraiser’s Office. After reviewing new evidence relevant to the case, it has been determined that the new lien amount is $5,104.11. The original lien amount was $5,168.75. This letter is intended to notify you of this change. In accordance with Florida Statute 196.161, the notice of tax lien was recorded with the Clerk of The Circuit Court. Upon full payment of this amount, a satisfaction of lien will be recorded by the Tax Collector's Office. If you have any questions regarding payment arrangements, please contact the Tax Collector's Office. Payment must be in the form of a cashier's check or money order made payable to the “Miami-Dade County Tax Collector” and mailed to the Tax Collector’s Office, 200 NW ana Avenue, Miami, Florida 33128. You may call the Tax Collector’s Office at (305) 270-4916. If you need to discuss the Property Appraiser’s decision with respect to your property, please call Mr. Julio Guas at (305) 375-4237 or (305) 375-3402. Sincerely, C. — > Ernesto Alonso CFE Investigations Supervisor Office of the Property Appraiser 111 NW 18T STREET, SUITE 710 + MIAMI, FLORIDA + 33128 PHONE: 305-375-3402 + FAX: 305-375-1912 WEB SITE: WWW,.MIAMIDADE.GOV/PAEXHIBIT E 45 NE 167™ STREET, NORTH MIAMI BEACH, FL 33162 TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495 AAGibson@Gibsontaxlaw.comANDRE GIBSON, CHARTERED TAX & BUSINESS ATTORNEYS ANDRE A. GIBSON LICENSED IN FLORIDA AND WISCONSIN MeMBER OF THE UNiTeD States SUPREME Court BAR LL.M. IN INTERNATIONAL TAXATION August 30, 2017 VIA FEDEX: 7701-5139-8474 Miami-Dade Tax Collector 200 NW 2™ Avenue Miami, FL 33128 Re: Tax Payment Under Protest: 31-2211-039-1220-HX-2013 Dear Tax Collector: Attached hereto is my client’s payment for the 2013 tax year Homestead Penalty levied against the captioned property. This payment is being made under protest as to the penalties and interest charged on the recapture tax levy. Please note that legal action will be forthcoming on the following basis: 1. Seeking a full refund of the interest and penalties charged in the recapture tax for 2013, 2. Challenging the denial of the homestead exemptions for 2014 through 2016 with the interest and penalties charged, and; 3. In the alternative: a. contesting the lack of legal basis to charge penalties and interest; and b._ the calculations of the basis for the levy of Homestead Penalty Tax Please process the attached check for the specified tax for tax year 2013. Should you have any questions, please contact me directly. Andre A. Gibson Attorney for Virginia Lopez and Raul Mejia Enclosure: 1, Attorney’s Trust Account Check No. 2874 Ce: Ely Gonzalez, Staff Attorney, Miami-Dade County Property Appraiser via email only Page 1 of 4 45 NE 167" STREET, NORTH MIAMI BEACH, FL 33162 TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495 ‘AAGibson@Gibsontaxlaw.comBip revrirtoonenesnaieasins Det ti Ny 2874 METH FR ANDRE GIBSON, CHARTERED wrsbayne pieagctny COMER THR? CUENT TRUST ACCOUNT aa ecaRE a NbW TN Mane BEACH, PLS3 168 eeeenaters SOROV? PE 305-682-4800 Ke ne Miami-Dade Tax Collector ff 75 A28. 78 Five Thousand Four Hundiéd Twenty-Four and 78/400" eetvewntestnervenntesconssevanenccoresventatscreeseeniweess Gy yp Miami-Dade Tax Collector 200 NW 2 Avenue Miami, FL A326 Under Protest 31-221 1-039-1220-HX-2013 “0028740 1: i 39° ANDRE GIBSON, CHARTERED/CLIENT TRUST ACCOUNT BT4 Miami-Dade Tex Collector BMVZOTT 2 Under Protest 34-221 1-O38-1280-HX-2013 SA24,78 Client Trust Accounts Under Protest: 34-2211-030-1220-HX-2013 5424.78 AMORE GIBSON, CHARTERED/CLIENT TRUST ACCOUNT 2874 Miam!-Dede Tax Collector BIOROT? Under Protest: 34-221 1-039-1220-HX-2013 5424.78 Ghent Trust Aecounts Under Protest: 31-2211-038-1220-HX-2013 5,434.78 a ce aicate public_user 08/30/2017 2013 Homestead Penalty Wn WN | | WM | PTET REP Bu2211-090-1220-HX wor st2/e27T1O591220HX+20135% if Received By Please Pay 201 178 DR 531 PROPERTY ADDRESS Make checks payable to: Miami-Dade Tax Collector Aug 31, 2017 $5,424.78 (in U.S, funds drawn on U.S. banks) iia-Dade Tex Colect | _Sep 30,2017 $5,458.48 __| LEGAL DESCRIPTION. a tEGes coneo Miami-Dade Tax Collector Sep 30,2017 $5,458.48 ONT 581 ose (in U.S. funds drawn on U.S. banks) INT IN COMMON ELEMENTS Amount due May be Subject to Change Without Notice Oct 31, 2017 $5,492.18 RAUL MEJIA VIRGINIA LOPEZ JTRS 201 178 DR #531 MIAMI, FL 33160-2898 9300000000000000031221103912e0HxX2013000002b95540000000000038/30/2017 FedEx Ship Manager - Print Your Label(s) a zB =leze °) Sz BEES 83 Ese weal ie nese = 85 SEB Gz S006 3 =B if 2228/2 2 s on Oo O| Be 28 = ~™ pEBES|sSE 9 g = es 8500/"2 = a = gg Omm = 4 8 = Baul § gs = 8 < g f ge = BE z a N = 20 = =] 4 moo S = ee = cc = mm =k gg 4 BF 3s = aa) 2 eae si Qo <25 Fe ZB RSS 3: B Bec of S52 s>P> 4 2 me 3 2S & Zw s 58 j uv srranrrmeatiue . 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Written claims must be filed within strict time limits, see current FedEx Service Guide. https://www.fedex.com/shipping/shipmentConfirmationAction.handle?method=doContinue 41EXHIBIT F 45 NE 167™ STREET, NORTH MIAMI BEACH, FL 33162 TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495 AAGibson@Gibsontaxlaw.comANDRE GIBSON, CHARTERED TAX & BUSINESS ATTORNEYS ANDRE A. GIBSON LiceNseDIN FLoriDA AND WiscoNs N Memeer of THE UNITED States Supreme Court BAR LLM. IN INTERNATIONAL TAXATION October 11, 2017 VIA FEDEX: 770470729056 Miami-Dade Tax Collector 200 NW 2™ Avenue Miami, FL 33128 Re: Tax Payment Under Protest: 31-2211-039-1220-HX-2014-2016 Dear Tax Collector: Please accept this letter as a correction to the letter related to this account dated October 9, 2017. (See attached). The asterisks herein denote changes. Attached hereto is my client’s good-faith payment for the recapture taxes and the relevant years. These payments are being made under protest as to the amount of the recapture tax levy. It is the taxpayer’s position that no interest and penalties are due for the applicable tax years, thus only the recapture tax levy for the respective years are paid: 1. Statutory Recapture Tax for Tax year 2014 $2,998.49 2. Statutory Recapture Tax for Tax year 2015 $2,925.97 3. Statutory Recapture Tax for Tax year 2016* $3,192.91 Please note that legal action will be forthcoming on the following basis: 1. Seeking a refund of the excess taxes, 2. Challenging the denial of the homestead exemptions for 2014 through 2016 with the interest and penalties charged, and: 3. In the alternative: a. contesting the lack of legal basis to charge penalties and interest; and b. the calculations of the basis for the levy of Homestead Penalty Tax Please process the attached checks for the specified tax for tax years 2014 — 2016*. Should you have any questions, please contact me directly Respectfully, he Andre A. Gibson Attomey for Virginia Lopez and Raul Mejia Enclosure 1. Copies of Check No. 2875 $2998.49; No. 2976 $2925.97; and No. 2877 $2,925.97 Ce: Ely Gonzalez, Staff Attorney, Miami-Dade County Property Appraiser via email only Page 1 of 4 45 NE 167™ STREET, NORTH MIAMI BEACH, FL 33162 TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495 AAGibson@Gibsontaxlaw.comANDRE GIBSON, CHARTERED TAX & BUSINESS ATTORNEYS ANDRE A. GIBSON LiceNseDIN FLoriDA AND WiscoNs N Memeer of THE UNITED States Supreme Court BAR LLM. IN INTERNATIONAL TAXATION October 9, 2017 VIA FEDEX: 7704-5059-5391 Miami-Dade Tax Collector 200 NW 2"! Avenue Miami, FL 33128 Re: Tax Payment Under Protest: 31-2211-039-1220-HX-2013 Dear Tax Collector: Attached hereto is my client’s good-faith payment for the recapture taxes and the relevant years. These payments are being made under protest as to the amount of the recapture tax levy. It is the taxpayer’s position that no interest and penalties are due for the applicable tax years, thus only the recapture tax levy for the respective year paid. 1. Statutory Recapture Tax for Tax year 2014 $2,998.49 2. Statutory Recapture Tax for Tax year 2015 $2,925.97 3. Statutory Recapture Tax for Tax year 2014 $3,192.91 Please note that legal action will be forthcoming on the following basis: 1. Seeking a refund of the excess taxes, 2. Challenging the denial of the homestead exemptions for 2014 through 2016 with the interest and penalties charged, and; 3. In the alternative a. contesting the lack of legal basis to charge penalties and interest; and b. the calculations of the basis for the levy of Homestead Penalty Tax Please process the attached check for the specified tax for tax year 2013. Should you have any questions, please contact me directly Respectfully, ¢ Andre A. Gibson Attorney for Virginia Lopez and Raul Mejia Enclosure: 1. Trust Account Check No. 2875 $2998.49; No. 2976 $2925.97; and No. 2877 $2,925.97 Cc: Ely Gonzalez, Staff Attorney, Miami-Dade County Property Appraiser via email only Page 1 of 4 ‘45 NE 167™ STREET, NORTH MIAMI BEACH, FL 33162 TELEPHONE: 305-652-4900 || TELEFAX: 305-808-3495 ‘AAGibson@Gibsontaxlaw.com2014 Homestead Penalty 31-2211-039-1220-HX FOLIO NUMBER 201 178 DR_531 PROPERTY ADDRESS LEGAL DESCRIPTION. LE CARTIER CONDO. UNIT 531 UNDIV .64496% NT IN COMMON ELEMENTS RAUL MEJIA 201 178 DR #531 MIAMI, FL 33160-2898 aot 31722711039 72208H Make checks payable to: Miami-Dade Tax Collector (in U.S. funds drawn on U.S. banks) Make checks payable to: Miami-Dade Tax Collector (in U.S. funds drawn on U.S. banks) x+2074 Amount due May be Subject to Change Without Notice icate public_user 10/09/2017 PAY ONLY ONE AMOUNT If Received By Please Pay Oct 31, 2017 $5,659.54 Nov 30, 2017 $5,697.02 Dec 31, 2017 $5,734.50 90000000000000003122110391220HxX20140000029944 30000000000080 amen 2875 ANDRE GIBSON, CHARTERED Piccoeugnenecitueiennetry CLENT TRUST ACCOUNT Take GoEANKe Bev 418 NW 163TH ST. STE. 26% ORTH MARE BEACH, 1, €x56) PORTH RUBE BE SSH, FL OS 168. RS RERZOTE qm9r0077 PH 2OS-BE2-4900 ph Ber Bee, @f Miami-Dade Tax Gallector 572.808.29 Twn Thousand Nine Hundred Ninety-Eight and 86/4 00*nesenrenscnscneeereerternenenerennentessstensemnrennenennns Miami-Dade Tax Callsctor 200 NW 2 Averuse Miami, FL 33128 | % Unster Profest! 31-221 1-4039-1220-HX-2014 002875 ANDRE GIBSON, CHARTERED/CLIENT TRUST ACCOUNT . 2875 Miami-Dade Tax Callector OAWZO1? Under Protect 31-2211-038-4220-HX-2014 2,998.49 Cent Trust Acoounts Under Protest 34-224 14039-4220-HX-2014 ZAR AQ ANDRE GIBSON, CHARTERED/CLIENT TRUST ACCOUNT 2875 Miami-Dade Tax Collector WOGRO? Uneer Profest 31-22 11-038-1220-HX-2014 2,988.48 Glient Trust Accounts Uncler Protest 31-22 71-099-1220-HX-2074 2,098.48 R HARE ee2015 Homestead Penalty 31-2211-039-1220-HX FOLIO NUMBER 201 178 DR 531 PROPERTY ADDRESS LEGAL DESCRIPTION. LE CARTIER CONDO. UNIT 531 UNDIV .64496% NT IN COMMON ELEMENTS RAUL MEJIA VIRGINIA LOPEZ JTRS 201 178 DR #531 MIAMI, FL 33160-2898 aot 31722711039 72208H Make checks payable to: Miami-Dade Tax Collector (in U.S. funds drawn on U.S. banks) Make checks payable to: Miami-Dade Tax Collector (in U.S. funds drawn on U.S. banks) Amount due May be Subject to Change Without Notice x+2015% ‘Additional Prior Year Property Taxes are Owed and Not Included in this Bill icate public_user 10/09/2017 PAY ONLY ONE AMOUNT If Received By Please Pay Oct 31, 2017 $5,093.88 Nov 30, 2017 $5,130.46 Dec 31, 2017 $5,167.02 90000000000000003122110391220HxX201500000292597000000010009Cy £5 Sos mainonn naoina Seoeense, 2876 ANDRE GIBSON. CHARTERED SSnaINE FNADEIAL SENTER TPR? ) CLIENT TRUST ACCOUNT 19285 SGAYNE BLVD 318 MW TBPTH ST.; STE, Bi MOTH Mish) BBACH, ML BSISS NORTH Nua BEACH, FL AGTBO BEBAUEED 1OGIO17 PH 308-682-8906 Liege BP os a Kee f_ Miami-Dade Tax Collector 282897 Two Thousand Nine Hundred Twenty-Five and O7/100ttrstsservsrennsnssetrneneuntennttnnnenntnnananenny Miami-Dade Tax Collector 200 NYY 2 Avenue Miami, FL 33428 He Under Protest: 31-22 11-039-4220-HS-2018 \ POO FR Poe ANDAE GIBSON, CHARTERED/GLIENT TRUST ACCOURT 2876 Miami-Dade Tax Catlectar 4QARIZO4? Under Protest: 34-2211-038-1220-HM-2018 2,985.97 Chant Trast Accounts Under Protest: $4-2211-036-1220-HX-2018 2825.87 ANDRE GIBSON, CHARTERED/CURRT TAUSY ACCOUNT 2876 Miami-Dade Tax Collector WYOROTT Under Protest 34-22 44-4098-1220-HX-BO15 2,925.97 Client Trust Aorounts Under Protest: 34-2214-099-1220-HX-2018 2825.87 SEUEREEE = casee2016 Homestead Penalty 31-2211-039-1220-HX FOLIO NUMBER 201 178 DR 531 PROPERTY ADDRESS LEGAL DESCRIPTION. LE CARTIER CONDO. UNIT 531 UNDIV .64496% NT IN COMMON ELEMENTS RAUL MEJIA VIRGINIA LOPEZ JTRS 201 178 DR #531 MIAMI, FL 33160-