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Roden v. K & K Land Management, Inc., 368 So.2d 588

Facts

K & K Land Management purchased approximately 350 acres of land, of which 325 acres were used as a producing citrus grove, while 25 acres were developed into an amusement park. The purchase price was six times the agricultural assessment, raising questions about the land's classification for tax purposes. The landowner sought a 'green belt' assessment, arguing that the land was still being used for bona fide agricultural purposes despite the high purchase price.

In this case K & K Land Management purchased approximately 350 acres of producing citrus grove for six times the agricultural assessment. Twenty-five of the acres were developed into an amusement park, but the remainder of the grove was continued to be used for citrus production.

Issue

Whether more than just agricultural use is required to establish that land may be classified as agricultural and entitled to preferential tax treatment.

The issue in conflict is whether more than just agricultural use is required to establish for purpose of tax assessment that land may be classified agricultural and be entitled, therefore, to preferential tax treatment.

Rule

'Agricultural use' is the test for classification of land as agricultural land entitled to preferential tax treatment, and the presumption of nonagricultural use can be rebutted by showing special circumstances demonstrating that the land is to be continued in bona fide agriculture.

'Agricultural use' is still the guidepost in classifying land, although other specifically enumerated factors relative to use may also be considered. Agricultural use is now and has always been the test.

Analysis

The court applied the rule by examining the circumstances surrounding the land's use and the purchase price. It found that the trial court correctly determined that special circumstances existed to rebut the presumption of nonagricultural use, as the majority of the land continued to be used for citrus production. The court emphasized that commercial success is not a necessary condition for rebuttal, and that the continued agricultural use of the land was sufficient.

Conclusion

The Supreme Court affirmed the decision of the District Court of Appeal, allowing the landowner to maintain the agricultural classification for the citrus grove.

The decision of the District Court is affirmed.

Who won?

K & K Land Management prevailed in the case because the court found that the presumption of nonagricultural use was successfully rebutted by the continued agricultural use of the majority of the land.

The District Court upheld the trial court's determination that there existed special circumstances sufficient to rebut the presumption.

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