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The Honorable Ed Crapo Alachua County Property Appraiser Post Office Box 23817 Gainesville, Florida 32602-3817

Dear Mr. Crapo:

You ask substantially the following question:

Where the owner of real property consisting of ninety acres and a house sells the property to the State of Florida but retains a life estate in the house and five acres, are the house and five acres subject to taxation?

In sum:

While property purchased by the state is immune from taxation, the retention of a life estate by the private seller of a portion of the property creates a freehold interest in that portion that is…