HB 6019 2025
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F L O R I D A H O U S E O F R E P R E S E N T A T I V E S
A bill to be entitled 1
An act relating to the state estate tax; repealing s. 2
198.01, F.S., relating to definitions; repealing s. 3
198.015, F.S., relating to domicile of decedent; 4
repealing s. 198.02, F.S., relating to tax upon 5
estates of resident decedents; repealing s. 198.021, 6
F.S., relating to tax upon generation -skipping 7
transfers of residents; repealing s. 198.03, F.S., 8
relating to tax upon estates of nonresident decedents; 9
repealing s. 198.031, F.S., relating to tax upon 10
generation-skipping transfers of nonresidents; 11
repealing s. 198.04, F.S., relating to tax upon 12
estates of alien decedents; repealing s. 198.05, F.S., 13
relating to administration of law by Department of 14
Revenue; repealing s. 198.06, F.S., relating to 15
examination of books, papers, records, or memoranda by 16
the department; repealing s. 198.07, F.S., relating to 17
appointment of agents by department, bonds of agents, 18
agents may administer oaths, and agent credentials; 19
repealing s. 198.08, F.S., relating to rules; 20
repealing s. 198.11, F.S., relating to appointment of 21
special appraisers; repealing s. 198.13, F.S., 22
relating to tax return to be made in certain cases and 23
certificate of nonliability; repealing s. 198.14, 24
F.S., relating to failure to make return and extension 25
HB 6019 2025
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F L O R I D A H O U S E O F R E P R E S E N T A T I V E S
of time for filing; repealing s. 198.15, F.S., 26
relating to when tax due, extension, interest, and 27
penalty; repealing s. 198.155, F.S., relating to 28
payment of tax on generation -skipping transfers; 29
repealing s. 198.16, F.S., relating to notice of 30
determination of deficiency in federal tax to be filed 31
with department; repealing s. 198.17, F.S., relating 32
to deficiency and hearing by department; repealing s. 33
198.18, F.S., relating to failure to pay tax, 34
penalties, delinquent or deficient taxes, and 35
interest; repealing s. 198.19, F.S., relating to 36
receipts for taxes; repealing s. 198.20, F.S., 37
relating to failure to pay tax when due and 38
department's warrant; repealing s. 198.21, F.S., 39
relating to tax due payable from entire estate and 40
third persons; repealing s. 198.22, F.S., relating to 41
lien for unpaid taxes; re pealing s. 198.23, F.S., 42
relating to personal liability of personal 43
representative; repealing s. 198.24, F.S., relating to 44
sale of real estate by personal representative to pay 45
tax; repealing s. 198.25, F.S., relating to actions to 46
enforce payment of tax; repealing s. 198.26, F.S., 47
relating to no discharge of personal representative 48
until tax is paid; repealing s. 198.28, F.S., relating 49
to time for assessment of tax; repealing s. 198.29, 50
HB 6019 2025
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F L O R I D A H O U S E O F R E P R E S E N T A T I V E S
F.S., relating to refunds of excess tax paid; 51
repealing s. 198.30, F.S ., relating to circuit judge 52
to report names of decedents; repealing s. 198.31, 53
F.S., relating to duties and powers of corporate 54
personal representatives of nonresident decedents; 55
repealing s. 198.32, F.S., relating to prima facie 56
liability for tax; repeal ing s. 198.33, F.S., relating 57
to discharge of estate, notice of lien, and limitation 58
on lien; repealing s. 198.34, F.S., relating to 59
disposition of proceeds from taxes; repealing s. 60
198.35, F.S., relating to interpretation and 61
construction; repealing s. 19 8.36, F.S., relating to 62
failure to produce records and penalty; repealing s. 63
198.37, F.S., relating to failure to make return and 64
penalty; repealing s. 198.38, F.S., relating to false 65
return and penalty; repealing s. 198.39, F.S., 66
relating to false stateme nt in return and penalty; 67
repealing s. 198.40, F.S., relating to failure to pay 68
tax, evasion of tax, and penalty; repealing s. 198.41, 69
F.S., relating to effectiveness of chapter; repealing 70
s. 198.42, F.S., relating to short title; repealing s. 71
198.44, F.S., relating to certain exemptions from 72
inheritance and estate taxes; amending ss. 213.015, 73
213.21, and 213.285, F.S; conforming cross -references 74
to changes made by the act; providing an effective 75
HB 6019 2025
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F L O R I D A H O U S E O F R E P R E S E N T A T I V E S
date. 76
77
Be It Enacted by the Legislature of the State of Florida: 78
79
Section 1. Sections 198.01, 198.015, 198.02, 198.021, 80
198.03, 198.031, 198.04, 198.05, 198.06, 198.07, 198.08, 198.11, 81
198.13, 198.14, 198.15, 198.155, 198.16, 198.17, 198.18, 198.19, 82
198.20, 198.21, 198.22, 198.23, 198.24, 198.25, 198.26, 1 98.28, 83
198.29, 198.30, 198.31, 198.32, 198.33, 198.34, 198.35, 198.36, 84
198.37, 198.38, 198.39, 198.40, 198.41, 198.42, and 198.44, 85
Florida Statutes, are repealed. 86
Section 2. Subsections (3), (6), and (11) of section 87
213.015, Florida Statutes, are amend ed to read: 88
213.015 Taxpayer rights. —There is created a Florida 89
Taxpayer's Bill of Rights to guarantee that the rights, privacy, 90
and property of Florida taxpayers are adequately safeguarded and 91
protected during tax assessment, collection, and enforcement 92
processes administered under the revenue laws of this state. The 93
Taxpayer's Bill of Rights compiles, in one document, brief but 94
comprehensive statements which explain, in simple, nontechnical 95
terms, the rights and obligations of the Department of Revenue 96
and taxpayers. Section 192.0105 provides additional rights 97
afforded to payors of property taxes and assessments. The rights 98
afforded taxpayers to ensure that their privacy and property are 99
safeguarded and protected during tax assessment and collection 100
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F L O R I D A H O U S E O F R E P R E S E N T A T I V E S
are available only insofar as they are implemented in other 101
parts of the Florida Statutes or rules of the Department of 102
Revenue. The rights so guaranteed Florida taxpayers in the 103
Florida Statutes and the departmental rules are: 104
(3) The right to be represente d or advised by counsel or 105
other qualified representatives at any time in administrative 106
interactions with the department, the right to procedural 107
safeguards with respect to recording of interviews during tax 108
determination or collection processes conducted by the 109
department, the right to be treated in a professional manner by 110
department personnel, and the right to have audits, inspections 111
of records, and interviews conducted at a reasonable time and 112
place except in criminal and internal investigations (see ss. 113
198.06, 199.218, 201.11(1), 203.02, 206.14, 211.125(3), 114
211.33(3), 212.0305(3), 212.12(5)(a), (6)(a), and (12), 115
212.13(5), 213.05, 213.21(1)(a) and (c), and 213.34). 116
(6) The right to be informed of impending collection 117
actions which require sale or s eizure of property or freezing of 118
assets, except jeopardy assessments, and the right to at least 119
30 days' notice in which to pay the liability or seek further 120
review (see ss. 198.20, 199.262, 201.16, 206.075, 206.24, 121
211.125(5), 212.03(5), 212.0305(3)(j), 212.04(7), 212.14(1), 122
213.73(3), 213.731, and 220.739). 123
(11) The right to procedures for requesting cancellation, 124
release, or modification of liens filed by the department and 125
HB 6019 2025
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F L O R I D A H O U S E O F R E P R E S E N T A T I V E S
for requesting that any lien which is filed in error be so noted 126
on the lien cancellation filed by the department, in public 127
notice, and in notice to any credit agency at the taxpayer's 128
request (see ss. 198.22, 199.262, 212.15(4), 213.733, and 129
220.819). 130
Section 3. Paragraph (a) of subsection (2) of section 131
213.21, Florida Statut es, is amended to read: 132
213.21 Informal conferences; compromises. — 133
(2)(a) The executive director of the department or his or 134
her designee is authorized to enter into closing agreements with 135
any taxpayer settling or compromising the taxpayer's liability 136
for any tax, interest, or penalty assessed under any of the 137
chapters specified in s. 72.011(1). Such agreements must be in 138
writing if the amount of tax, penalty, or interest compromised 139
exceeds $30,000, or for lesser amounts, if the department deems 140
it appropriate or if requested by the taxpayer. When a written 141
closing agreement has been approved by the department and signed 142
by the executive director or his or her designee and the 143
taxpayer, it shall be final and conclusive; and, except upon a 144
showing of fraud or misrepresentation of material fact or except 145
as to adjustments pursuant to s. 220.23 ss. 198.16 and 220.23 , 146
no additional assessment may be made by the department against 147
the taxpayer for the tax, interest, or penalty specified in the 148
closing agreement for the time period specified in the closing 149
agreement, and the taxpayer is not entitled to institute any 150
HB 6019 2025
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F L O R I D A H O U S E O F R E P R E S E N T A T I V E S
judicial or administrative proceeding to recover any tax, 151
interest, or penalty paid pursuant to the closing agreement. The 152
department is authorize d to delegate to the executive director 153
the authority to approve any such closing agreement resulting in 154
a tax reduction of $500,000 or less. 155
Section 4. Subsection (6) of section 213.285, Florida 156
Statutes, is amended to read: 157
213.285 Certified audits .— 158
(6) The department shall review the report of the 159
certified audit and shall accept it when it is determined to be 160
complete. Once the report is accepted by the department, the 161
department shall issue a notice of proposed assessment 162
reflecting the determ ination of any additional liability 163
reflected in the report and shall provide the taxpayer with all 164
the normal payment, protest, and appeal rights with respect to 165
the liability. In cases where the report indicates an 166
overpayment has been made, the taxpayer shall submit a properly 167
executed application for refund to the department. Otherwise, 168
the certified audit report is a final and conclusive 169
determination with respect to the tax and period covered. No 170
additional assessment may be made by the department for the 171
specific taxes and period referenced in the report, except upon 172
a showing of fraud or misrepresentation of material facts and 173
except for adjustments made under s. 198.16 or s. 220.23. This 174
determination shall not prevent the department from collecting 175
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liabilities not covered by the report or from conducting an 176
audit or investigation and making an assessment for additional 177
tax, penalty, or interest for any tax or period not covered by 178
the report. 179
Section 5. This act shall take effect upon becoming a law. 180