Fla. Stat. 198.22
Lien for unpaid taxes

Unless the tax is sooner paid in full, it shall be a lien for 12 years upon the gross estate of the decedent, except that such part of the gross estate as is used for the payment of charges against the estate and expenses of its administration, allowed by any court having jurisdiction thereof, shall be divested of such lien, and except that such part of the gross estate of a resident decedent as is transferred to a bona fide purchaser, mortgagee, or pledgee, for an adequate and full consideration in money or money’s worth shall be divested of such lien and such lien shall then attach to the consideration received for such property from such purchaser, mortgagee, or pledgee. If the department is satisfied that no tax liability exists or that the tax liability of an estate has been fully discharged or provided for, it may issue a waiver releasing any or all property of such estate from the lien herein imposed.

Source: Section 198.22 — Lien for unpaid taxes, https://www.­flsenate.­gov/Laws/Statutes/2024/0198.­22 (accessed Aug. 7, 2025).

198.01
Definitions 198.02
Tax upon estates of resident decedents 198.03
Tax upon estates of nonresident decedents 198.04
Tax upon estates of alien decedents 198.05
Administration of law by Department of Revenue 198.06
Examination of books, papers, records, or memoranda by the department 198.07
Appointment of agents by department 198.08
Rules 198.11
Appointment of special appraisers 198.13
Tax return to be made in certain cases 198.14
Failure to make return 198.15
When tax due 198.015
Domicile of decedent 198.16
Notice of determination of deficiency in federal tax to be filed with department 198.17
Deficiency 198.18
Failure to pay tax 198.19
Receipts for taxes 198.20
Failure to pay tax when due, department’s warrant, etc 198.21
Tax due payable from entire estate 198.021
Tax upon generation-skipping transfers of residents 198.22
Lien for unpaid taxes 198.23
Personal liability of personal representative 198.24
Sale of real estate by personal representative to pay tax 198.25
Actions to enforce payment of tax 198.26
No discharge of personal representative until tax is paid 198.28
Time for assessment of tax 198.29
Refunds of excess tax paid 198.30
Circuit judge to report names of decedents, etc 198.31
Duties and powers of corporate personal representatives of nonresident decedents 198.031
Tax upon generation-skipping transfers of nonresidents 198.32
Prima facie liability for tax 198.33
Discharge of estate, notice of lien, limitation on lien, etc 198.34
Disposition of proceeds from taxes 198.35
Interpretation and construction 198.36
Failure to produce records 198.37
Failure to make return 198.38
False return 198.39
False statement in return 198.40
Failure to pay tax, evasion of tax, etc. 198.41
Effectiveness of this chapter, etc 198.42
Short title 198.44
Certain exemptions from inheritance and estate taxes 198.155
Payment of tax on generation-skipping transfers

Current through Fall 2025

§ 198.22. Lien for unpaid taxes's source at flsenate​.gov