Division of Administrative Hearings, Florida
Filed: Feb. 09, 2011
The issues in this case are: (1) whether portions of Florida Administrative Code Rules 12D-9.020 and 12D-9.025 constitute invalid exercises of delegated legislative authority; (2) whether sections of Modules Four and Six of the 2010 Value Adjustment Board Training are unpromulgated rules; and (3) whether Property Tax Oversight Bulletin 11-01 is an unpromulgated rule.To the extent that rule 12D-9.020 provides that taxpayers are under no obligation to disclose their evidence prior to VAB hearings, the rule contravenes section 194.011(4)(a). 2010 VAB Training and PTO Bulletin 11-01 do not constitute unadopted rules.
