W. SHARP, J.
Petitioner, the Department of Revenue, seeks a writ of prohibition to require the trial court to dismiss a declaratory judgment action on the ground that the court lacks subject matter jurisdiction over the issues involved, because respondents failed to file actions in court or petitions with the Value Adjustment Board to contest the assessment of ad valorem taxes within sixty days, as mandated by section 194.171(2), Florida Statutes (1999).
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