Home
Menu
Call attorney Graham Syfert at 904-383-7448
Personal Injury Lawyer
Florida Statute 197.522 | Lawyer Caselaw & Research
F.S. 197.522 Case Law from Google Scholar
Statute is currently reporting as:
Link to State of Florida Official Statute Google Search for Amendments to 197.522

The 2023 Florida Statutes (including Special Session C)

Title XIV
TAXATION AND FINANCE
Chapter 197
TAX COLLECTIONS, SALES, AND LIENS
View Entire Chapter
F.S. 197.522
197.522 Notice to owner when application for tax deed is made.
(1)(a) The clerk of the circuit court shall notify, by certified mail with return receipt requested or by registered mail if the notice is to be sent outside the continental United States, the persons listed in the tax collector’s statement pursuant to s. 197.502(4) that an application for a tax deed has been made. Such notice shall be mailed at least 20 days prior to the date of sale. If no address is listed in the tax collector’s statement, then no notice shall be required.
(b) The clerk shall enclose with every copy mailed a statement as follows:

WARNING: There are unpaid taxes on property which you own or in which you have a legal interest. The property will be sold at public auction on   (date)   unless the back taxes are paid. To make payment, or to receive further information, contact the clerk of court immediately at   (address)  ,   (telephone number)  .

(c) The clerk shall complete and attach to the affidavit of the publisher a certificate containing the names and addresses of those persons notified and the date the notice was mailed. The certificate shall be signed by the clerk and the clerk’s official seal affixed. The certificate shall be prima facie evidence of the fact that the notice was mailed. If no address is listed on the tax collector’s certification, the clerk shall execute a certificate to that effect.
(d) The failure of anyone to receive notice as provided herein shall not affect the validity of the tax deed issued pursuant to the notice.
(e) A printed copy of the notice as published in the newspaper, accompanied by the warning statement described in paragraph (b), shall be deemed sufficient notice.
(2)(a) In addition to the notice provided in subsection (1), the sheriff of the county in which the legal titleholder resides shall, at least 20 days prior to the date of sale, notify the legal titleholder of record of the property on which the tax certificate is outstanding. The original notice and sufficient copies shall be prepared by the clerk and provided to the sheriff. Such notice shall be served as specified in chapter 48; if the sheriff is unable to make service, he or she shall post a copy of the notice in a conspicuous place at the legal titleholder’s last known address. The inability of the sheriff to serve notice on the legal titleholder shall not affect the validity of the tax deed issued pursuant to the notice. A legal titleholder of record who resides outside the state may be notified by the clerk as provided in subsection (1). The notice shall be in substantially the following form:

WARNING

There are unpaid taxes on the property which you own. The property will be sold at public auction on   (date)   unless the back taxes are paid. To make arrangements for payment, or to receive further information, contact the clerk of court at   (address)  ,   (telephone number)  .

In addition, if the legal titleholder does not reside in the county in which the property to be sold is located, a copy of such notice shall be posted in a conspicuous place on the property by the sheriff of the county in which the property is located. However, no posting of notice shall be required if the property to be sold is classified for assessment purposes, according to use classifications established by the department, as nonagricultural acreage or vacant land.

(b) In addition to the notice provided in subsection (1), the clerk shall notify by certified mail with return receipt requested, or by registered mail if the notice is to be sent outside the continental United States, the persons listed in the tax collector’s statement pursuant to s. 197.502(4)(h) that application for a tax deed has been made. Such notice shall be mailed at least 20 days prior to the date of sale. If no address is listed in the tax collector’s statement, then no notice shall be required. Enclosed with the copy of the notice shall be a statement in substantially the following form:

WARNING

There are unpaid taxes on property contiguous to your property. The property with the unpaid taxes will be sold at auction on   (date)   unless the back taxes are paid. To make payment, or to receive further information about the purchase of the property, contact the clerk of court immediately at   (address)  ,   (telephone number)  .

Neither the failure of the tax collector to include the list of contiguous property owners pursuant to s. 197.502(4)(h) in his or her statement to the clerk nor the failure of the clerk to mail this notice to any or all of the persons listed in the tax collector’s statement pursuant to s. 197.502(4)(h) shall be a basis to challenge the validity of the tax deed issued pursuant to any notice under this section.

(3) When sending or serving a notice under this section, the clerk of the circuit court may rely on the addresses provided by the tax collector based on the certified tax roll and property information reports. The clerk of the circuit court has no duty to seek further information as to the validity of such addresses, because property owners are presumed to know that taxes are due and payable annually under s. 197.122.
(4) Nothing in this chapter shall be construed to prevent the tax collector, or any other public official, in his or her discretion from giving additional notice in any form concerning tax certificates and tax sales beyond the minimum requirements of this chapter.
History.s. 4, ch. 17457, 1935; CGL 1936 Supp. 999(139); s. 28, ch. 20722, 1941; s. 11, ch. 22079, 1943; ss. 1, 2, ch. 69-55; s. 1, ch. 72-268; s. 20, ch. 73-332; s. 1, ch. 75-192; s. 1, ch. 77-174; s. 8, ch. 79-584; s. 3, ch. 81-284; s. 189, ch. 85-342; s. 1026, ch. 95-147; s. 3, ch. 2003-284; s. 2, ch. 2018-160.
Note.Former ss. 194.18, 197.505, 197.256.

F.S. 197.522 on Google Scholar

F.S. 197.522 on Casetext

Amendments to 197.522


Arrestable Offenses / Crimes under Fla. Stat. 197.522
Level: Degree
Misdemeanor/Felony: First/Second/Third

Current data shows no reason an arrest or criminal charge should have occurred directly under Florida Statute 197.522.



Annotations, Discussions, Cases:

Cases from cite.case.law:

RAHIMI, v. GLOBAL DISCOVERIES, LTD. LLC,, 252 So. 3d 804 (Fla. App. Ct. 2018)

. . . Id. § 197.522(1)(a). . . . Section 197.522(1)(a) then references section 197.502(4): The tax collector shall deliver to the clerk . . . Section 197.522(1)(a) refers to "the persons listed in the tax collector's statement pursuant to section . . . Id. § 197.522(1)(a). . . . Id. § 197.522. . . .

THOMPSON, v. N. MARKHAM A., 164 So. 3d 1289 (Fla. Dist. Ct. App. 2015)

. . . invalid because she never received proper notice of the tax deed application in violation of section 197.522 . . . the court found the Columbia County Clerk of Court complied fully with the requirements of section 197.522 . . . It is undisputed that the Columbia County Clerk of Court complied with section 197.522(1), Florida Statutes . . .

H. MUNTZING, III, v. GLOBAL DISCOVERIES LTD. LLC,, 112 So. 3d 690 (Fla. Dist. Ct. App. 2013)

. . . See §§ 197.'502(4), 197.522(l)(a), 197.582(2), Fla. Stat. (2012); Fla. . . .

D. SRYGLEY Z. v. CAPITAL PLAZA, INC. a, 82 So. 3d 1211 (Fla. Dist. Ct. App. 2012)

. . . pursuant to a tax deed it obtained through the tax deed sale process set forth in sections 197.512, 197.522 . . . a tax deed has been made, and it must be mailed at least twenty days before the date of the sale. § 197.522 . . . However, Appellants cite no statutory language or case law suggesting that section 197.522(l)(a) has . . . clerk’s notification duties for all subsequent tax deed sales belies Appellants’ claim that section 197.522 . . . The Legislature’s precise description of the initial notice requirements in section 197.522(l)(a) indicates . . .

DELTA PROPERTY MANAGEMENT, v. PROFILE INVESTMENTS, INC., 87 So. 3d 765 (Fla. 2012)

. . . tax deed was valid because it was undisputed that notice was sent to Delta in accordance with section 197.522 . . . was invalid because the Clerk failed to comply with the notice requirements of sections 197.502 and 197.522 . . . Saada, 608 So.2d 806, 808 (Fla.1992), we concluded that section 197.522(1) mandates “notice reasonably . . . Delta asserts that because the Clerk knew the notice mailed pursuant to section 197.522 was ineffective . . . If the titleholder's last known address is in the State of Florida, section 197.522(2), Florida Statutes . . .

SURNA CONSTRUCTION, INC. v. MORRILL,, 50 So. 3d 47 (Fla. Dist. Ct. App. 2010)

. . . (l)(a) and the other under section 197.522(2)(b). . . . Having determined that Morrill was entitled to notice under both section 197.522(l)(a) and (2)(b), we . . . (1) and from the sheriff under section 197.522(2)(a). . . . The clerk complied with the notice requirements of section 197.522(1). . . . 1) and directory notice under section 197.522(2) (b). . . .

TURNBERRY INVESTMENTS, INC. a v. STREATFIELD,, 48 So. 3d 180 (Fla. Dist. Ct. App. 2010)

. . . of the tax certificate ... may file the certificate and an application for a tax deed.... ”). .See § 197.522 . . .

PROFILE INVESTMENTS, INC. v. DELTA PROPERTY MANAGEMENT, INC. a CIT a f k a AT T, 19 So. 3d 1013 (Fla. Dist. Ct. App. 2009)

. . . legal issue being whether the clerk had complied with the statutory notice requirements of section 197.522 . . . notices of tax sales, the Florida Supreme Court construed the relevant statutes as follows: Section 197.522 . . . The Florida Supreme Court specifically avoided any consideration of whether section 197.522 is facially . . . here that the learned trial judge, intending in good faith to apply the rule of Vosilla, found section 197.522 . . .

SOUTH INVESTMENT PROPERTIES, INC. v. ICON INVESTMENTS, LLC,, 988 So. 2d 1114 (Fla. Dist. Ct. App. 2008)

. . . Pursuant to section 197.522(l)(a), Florida Statutes (2005), the clerk sent notice of application for . . . Section 197.522(l)(a) states that the clerk of the circuit court shall notify, by certified mail with . . . However, section 197.522(l)(d), Florida Statutes (2000), states that the “failure of anyone to receive . . . Saada, 608 So.2d 806, 808 (Fla.1992) (alteration in original) (quoting § 197.522(l)(d), Fla. . . . The clerk complied with the provisions of section 197.522(l)(a) by sending notice by certified mail to . . .

DEUTSCH, v. GLOBAL FINANCIAL SERVICES, LLC M. a k a E. A. W. N. J., 976 So. 2d 680 (Fla. Dist. Ct. App. 2008)

. . . Section 197.522, Florida Statutes (2003), is titled, “Notice to owner when application for tax deed is . . . When such an application is made, section 197.522(l)(a) requires the clerk of the circuit court to give . . . However, if no address is listed in the tax collector’s statement, then notice is not required. § 197.522 . . . property owner that the property is scheduled for a tax deed sale, sent in compliance with section 197.522 . . .

PATRICIA WEINGARTEN ASSOCIATES, INC. v. JOCALBRO, INC. C., 974 So. 2d 559 (Fla. Dist. Ct. App. 2008)

. . . Section 197.522, Florida Statutes (2004), prescribes the procedures for notifying a property owner when . . . Relevant to this appeal is section 197.522(l)(a), which mandates that the Clerk of the Circuit Court . . . However, “ 'the failure of anyone to receive notice’ as provided in section 197.522(1) does not affect . . . Saada, 608 So.2d 806, 808 (Fla.1992) (quoting section 197.522(1)(d), Florida Statutes (1987)), provided . . . See generally § 197.522(3), Fla. . . .

SINGLETON v. ELI B. INVESTMENT CORP. a, 968 So. 2d 702 (Fla. Dist. Ct. App. 2007)

. . . They further asserted that section 197.522, Florida Statutes, which governs notice to an owner when application . . . Section 197.522, Florida Statutes, prescribes the procedures for notifying a property owner when an application . . . conflict issue: whether notice to a property owner of a pending tax deed sale that complies with section 197.522 . . .

MIAMI- DADE COUNTY v. BLUE MOUNTAIN INVESTMENT, INC., 962 So. 2d 921 (Fla. Dist. Ct. App. 2007)

. . . See §§ 197.502(4), 197.522(l)(a), Fla. Stat. (1993). . . .

GREENTREE SERVICING, LLC, v. J. DECANIO,, 948 So. 2d 1033 (Fla. Dist. Ct. App. 2007)

. . . Greentree centers its argument on section 197.522, Florida Statutes (2004). Mr. . . . Section 197.522(l)(a) provides that: The clerk of the circuit court shall notify, by certified mail with . . . Section 197.502(4), Florida Statutes (2004), the statute referenced in section 197.522(l)(a), lists the . . . The relevant issue is whether the clerk complies with the notice requirements of section 197.522, not . . . The court held further that “the failure of anyone to receive notice as provided in section 197.522(1 . . .

VOSILLA, v. ROSADO,, 944 So. 2d 289 (Fla. 2006)

. . . property owner that the property is scheduled for a tax deed sale, sent in compliance with section 197.522 . . . Sections 197.522(l)(a) and 197.502(4)(a), Florida Statutes (2000), require the clerk of court to mail . . . This issue does not require us to determine whether section 197.522(1) is facially constitutional. . . . Saada, 608 So.2d 806, 808 (Fla.1992) (alteration in original) (quoting § 197.522(l)(d), Fla. . . . as section 197.522(1). . . .

PATRICIA WEINGARTEN ASSOCIATES, INC. v. JOCALBRO, INC. C., 932 So. 2d 587 (Fla. Dist. Ct. App. 2006)

. . . Weingarten alleges the notice sent by the Clerk pursuant to the mandatory notice requirements of section 197.522 . . . GRIFFIN and PALMER, JJ., concur. . 197.522. . . .

JONES v. FLOWERS, 547 U.S. 220 (U.S. 2006)

. . . . § 197.522(2)(a) (2003); Minn. Stat. §281.23, subd. 6; S. C. Code Ann. § 12-51-40(c) (Supp. 2005). . . .

BOZEMAN, v. HIGGINBOTHAM,, 923 So. 2d 535 (Fla. Dist. Ct. App. 2006)

. . . Appellant argues that, because the tax collector complied with the statutory requirements of section 197.522 . . . address Higginbotham had listed as his address and was his last known address, as required by section 197.522 . . . If the clerk complies with the requirements of section 197.522(l)(a), as the clerk did here, the failure . . . See § 197.522(l)(d), Fla. Stat.; Dawson v. Saada, 608 So.2d 806 (Fla.1992). . . .

ROSADO v. VOSILLA,, 909 So. 2d 505 (Fla. Dist. Ct. App. 2005)

. . . Pursuant to Sections 197.522(l)(a) and 197.502(4)(a) Fla. . . . They note that the court in Dawson stated that “[sjection 197.522(1) meets constitutional due process . . . First, the issue in Dawson was not whether section 197.522(1) was constitutional. . . . It was whether failure to comply with section 197.522(2) was constitutional. . . . And the clerk of court sends the notice out pursuant to section 197.522(l)(a), Florida Statutes (2000 . . .

DELTA PROPERTY MANAGEMENT, INC. v. PROFILE INVESTMENTS, INC., 875 So. 2d 443 (Fla. 2004)

. . . See § 197.522(1), Fla. Stat. (1999). . . . I do not understand sections 197.502(4)(a) and 197.522(l)(a) to impose any such burden on the clerk. . . . Section 197.522(1)(a) unequivocally indicates that the clerk of the circuit court must notify by mail . . . This includes proper notice by the clerk pursuant to section 197.502(4) and section 197.522(l)(a). . . . See § 197.522(l)(a), Fla. Stat. (1999). . . .

HUTCHINSON ISLAND REALTY, INC. v. BABCOCK VENTURES, INC., 867 So. 2d 528 (Fla. Dist. Ct. App. 2004)

. . . receipt of the tax collector’s statement, the clerk is required to notify the persons listed in it. § 197.522 . . . Section 197.522(1) provides: The clerk of the circuit court shall notify, by certified mail with return . . . “Section 197.522(1) meets constitutional due process requirements by mandating notice reasonably calculated . . . In the instant case, the due process notice requirements of section 197.522(1) were met by the clerk . . . Under Dawson, if the notice requirements of section 197.522(1) are met, a sale of real property for the . . .

VOICE STREAM PCS I, LLC, d b a T- v. CITY OF HILLSBORO,, 301 F. Supp. 2d 1251 (D. Or. 2004)

. . . See ORS § 197.522 (providing that local government can deny a permit application when it "cannot be made . . .

S. BARON, I. v. RHETT a, 847 So. 2d 1032 (Fla. Dist. Ct. App. 2003)

. . . Section 197.522(l)(a), Florida Statutes, states: The clerk of the circuit court shall notify, by certified . . . In doing so, he reasoned that when sections 197.502(4)(a) and 197.522(l)(a) are read in pari materia, . . . Judge Ervin concluded: I do not understand sections 197.502(4)(a) and 197.522(l)(a) to impose [an onerous . . . In its final summary judgment, the trial court recognized that section 197.522 does not state how soon . . . The court further stated: Section 197.522, Florida Statutes should be construed to required that the . . .

DELTA PROPERTY MANAGEMENT, v. PROFILE INVESTMENTS, INC., 830 So. 2d 867 (Fla. Dist. Ct. App. 2002)

. . . legal issue being whether the clerk had complied with the statutory notice requirements of section 197.522 . . . Section 197.522(1) then requires the clerk of the circuit court to notify by mail the persons listed . . . It then deleted all requirements in section 197.256 (renumbered as 197.522) that the clerk perform a . . . The dissent would effectively rescind the 1985 statutory enactments by construing section 197.522(l)( . . . Section 197.522(l)(a) is therefore properly read to mean that the clerk satisfies the statu-toiy directive . . . The specific procedure regarding the mailing of the tax sale notice is set out in section 197.522(l)( . . . Saada, 608 So.2d 806, 808 (Fla.1992), the Florida Supreme Court made a distinction between section 197.522 . . . (1), pertaining to the clerk’s mailing of a pending tax sale notice, and section 197.522(2), which requires . . . Florida Supreme Court clearly stated that strict compliance with the mailing provisions of section 197.522 . . . I do not understand sections 197.502(4)(a) and 197.522(l)(a) to impose any such burden on the clerk. . . .

MILLER n k a N. A. n k a v. P. KNAPP,, 823 So. 2d 203 (Fla. Dist. Ct. App. 2002)

. . . As the court explained in Dawson: “section 197.522(1) meets constitutional due process requirements by . . . Section 197.522(2) provides an additional opportunity for owners of tax-delinquent property to redeem . . . the sheriff to serve notice upon the titleholder would ‘not affect the validity of the tax deed.’ § 197.522 . . . Moreover, ‘[t]he failure of anyone to receive notice’ as provided in section 197.522(1) does not affect . . . “Based upon the plain language of section 197.522, we find that subsection (1) specifies the mandatory . . .

KIDDER, v. CIRELLI, E., 821 So. 2d 1106 (Fla. Dist. Ct. App. 2002)

. . . priority of address in notification is ameliorated and perhaps explained by the requirement in section 197.522 . . . Thus, the test for the validity of notice under section 197.522(1)(a), Florida Statutes, is not merely . . .

In LAMBERT, E. Jr. v. M. B., 273 B.R. 663 (Bankr. N.D. Fla. 2002)

. . . . § 197.522(l)(a). . . . F.S. § 197.522(l)(b). . . .

R. BOSTWICK F. v. G. CLUKIES,, 801 So. 2d 961 (Fla. Dist. Ct. App. 2001)

. . . Neither Section 197.502(4), Florida Statutes, nor section 197.522(1), Florida Statutes, requires the . . .

Al SAGGESE, v. DEPARTMENT OF REVENUE OF STATE OF FLORIDA,, 770 So. 2d 1244 (Fla. Dist. Ct. App. 2000)

. . . Section 197.522(1), Florida Statutes (1999), the statutory notice to an owner when an application for . . . Even the failure of someone to receive notice as provided in section 197.522(1), does “not affect the . . . Daivson, 608 So.2d at 808; see § 197.522(l)(d), Fla. Stat. (1999). . . . Section 197.522(l)(a), states that while the clerk of the circuit court “shall notify” a property owner . . . send notice to proper address rendered tax deed sale invalid because notices complied with section 197.522 . . .

EUROFUND FORTY- SIX, LTD. v. J. TERRY J., 755 So. 2d 835 (Fla. Dist. Ct. App. 2000)

. . . court sent notices to the addresses listed on the tax collector’s statement, as required by section 197.522 . . .

LITTLE v. D ALOIA d b a DWDW, 759 So. 2d 17 (Fla. Dist. Ct. App. 2000)

. . . Dawson, 608 So.2d at 810 (holding that posting of notice procedures outlined in section 197.522(2), Florida . . . rather than jurisdictional and that as long as mandatory statutory notification procedures of section 197.522 . . . issued by a municipal clerk after the clerk complied with the mandatory notice requirements of section 197.522 . . . Florida Statutes (1987), but the clerk failed to comply with the notification requirements of section 197.522 . . .

D. CRANE v. MARTIN,, 741 So. 2d 1251 (Fla. Dist. Ct. App. 1999)

. . . jurisdictional, and because the clerk of the circuit court complied with the statutory requirements of section 197.522 . . . tax deed, “provided that there has been compliance with the notice [by mail] requirements of section 197.522 . . . The court noted that the service of notice provisions of section 197.522(2) simply provides “an additional . . . Section 197.522(l)(d) expressly provides: “The failure of anyone to receive notice as provided herein . . . There was no evidence below that the clerk of the court failed to comply with section 197.522(1). . . .

BULLOCK, v. HOUSTON REALTY INVESTMENT, INC., 739 So. 2d 1251 (Fla. Dist. Ct. App. 1999)

. . . We begin this analysis by discussing the notice requirements of section 197.522(l)(a), Florida Statutes . . . collector’s statement pursuant to s. 197.502(4) that an application for a tax deed has been made.” § 197.522 . . . that “[i]f no address is listed in the tax collector’s statement, then no notice shall be required.” § 197.522 . . . Broward County, 718 So.2d 197 (Fla. 4th DCA 1998), this court considered sections 197.522 and 197.502 . . . Co., 648 So.2d 210 (Fla. 4th DCA 1994) ], it is clear that the purpose of sections 197.522 and 197.502 . . .

KERR, v. BROWARD COUNTY, a L., 718 So. 2d 197 (Fla. Dist. Ct. App. 1998)

. . . Any remaining surplus shall be “retained by the clerk for the benefit of the persons described in s. 197.522 . . . Section 197.522(l)(a) states that the clerk of the court shall notify “the persons listed in the tax . . . If no address is listed in the tax collector’s statement, then no notice shall be required.” § 197.522 . . . form concerning tax certificates and tax sales beyond the minimum requirements of this chapter.” § 197.522 . . . Based on Dawson and DeMario, it is clear that the purpose of sections 197.522 and 197.502 is to provide . . .

P. EVANS, Jr. v. S. IRELAND,, 707 So. 2d 1135 (Fla. Dist. Ct. App. 1998)

. . . on the information received from the Tax Collector, the Clerk of Court then, as required by section 197.522 . . . See § 197.522(l)(d), Fla. Stat. (1995). In Dawson v. . . . Section 197.522(l)(d), Florida Statutes (1995), provides that "failure to receive notice as provided . . .

TERRA MAR CAPITAL, INC. T. D. v. AUXIER, 694 So. 2d 779 (Fla. Dist. Ct. App. 1997)

. . . Section 197.522(l)(a), Florida Statutes (1993) provides the notice which must be given to an owner in . . . this ease: 197.522 Notice to owner when application for tax deed is made.- (l)(a) The clerk of the circuit . . .

C. SKELTON, v. MARTIN, C. K., 673 So. 2d 877 (Fla. Dist. Ct. App. 1996)

. . . . § 197.522(1), Fla.Stat. (1991). The clerk also notified the mortgagees of record. . . .

DeMARIO A. H. v. FRANKLIN MORTGAGE INVESTMENT CO. INC., 648 So. 2d 210 (Fla. Dist. Ct. App. 1994)

. . . balance of the purchase price shall be retained by the clerk for the benefit of persons described in s. 197.522 . . . Sections 197.502(4) and 197.522(l)(a), Florida Statutes (1993), combine to require that the required . . .

UNITED STATES v. MARION COUNTY, FLORIDA,, 826 F. Supp. 1400 (M.D. Fla. 1993)

. . . . § 197.522; otherwise, the tax deed may be declared void. Jernigan v. . . . Fla.Stat. § 197.522(1)(d). . . .

SAADA S. v. DAWSON, Sr., 612 So. 2d 728 (Fla. Dist. Ct. App. 1993)

. . . Section 197.522(2), Florida Statutes (1987), provides in part: In addition to the notice provided in . . .

DAWSON, Sr. v. SAADA,, 608 So. 2d 806 (Fla. 1992)

. . . as one of great public importance: WHETHER FAILURE TO COMPLY WITH THE NOTICE REQUIREMENTS OF SECTION 197.522 . . . Section 197.522 sets forth the procedure for giving notice to property owners that a tax sale purchaser . . . Section 197.522(1) provides in relevant part: (1)(a) The clerk of the circuit court shall notify, by . . . The record reflects that the clerk complied with the notice requirements of section 197.522(1). . . . However, the sheriff was unable to serve the additional notice provided by section 197.522(2) because . . .

HAMPTON ENTERPRISES, INC. a v. ADELMAN,, 596 So. 2d 1134 (Fla. Dist. Ct. App. 1992)

. . . no error by the trial court in setting aside a tax sale because the notice requirements of section 197.522 . . .

SAADA S. v. DAWSON, Sr., 573 So. 2d 1008 (Fla. Dist. Ct. App. 1991)

. . . Section 197.522, Florida Statutes, sets forth the procedure for noticing titleholders upon an application . . . as one of great public importance: WHETHER FAILURE TO COMPLY WITH THE NOTICE REQUIREMENTS OF SECTION 197.522 . . .

GENERAL ELECTRIC CAPITAL CORPORATION, v. SOHN,, 566 So. 2d 841 (Fla. Dist. Ct. App. 1990)

. . . out that the holder of such a perfected security interest is nevertheless not entitled under Section 197.522 . . .

S. ALWANI v. G. SLOCUM A. P. E. H., 540 So. 2d 908 (Fla. Dist. Ct. App. 1989)

. . . Section 197.522(l)(a), Florida Statutes (1987), provides, “The clerk of the circuit court shall notify . . . Also to no avail is appellants’ argument that the lack of a requirement in section 197.522 that the clerk . . . for the same reasons, do we conclude with reference to other contentions of appellants that section 197.522 . . .

D. R. L. INC. v. W. MURPHY A., 508 So. 2d 413 (Fla. Dist. Ct. App. 1987)

. . . Section 197.522, Florida Statutes (1985), formerly section 197.256, Florida Statutes. . . . .

HIGH POINT CONDOMINIUM RESORTS, LTD. v. DAY,, 494 So. 2d 508 (Fla. Dist. Ct. App. 1986)

. . . .-522(l)(a), (b), 197.522(2), Fla.Stat.) — timeshare owners are not. . . .