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Disney Files 12 Complaints Challenging Florida Property Tax Assessments

Florida property tax lawyer, Jeanette Moffa, Jeanette Moffa tax lawyer, Moffa Sutton Donnini, James H. Sutton, Jr. tax, Joseph Moffa tax lawyer, florida tax audit defense, florida department of revenue

Disney Sues Orange County Over Property Tax Assessments on Hotels, Parks, and Iconic Assets

ORLANDO, FL — April 2025
In a bold and sweeping legal maneuver, Walt Disney Parks and Resorts U.S., Inc. has filed 12 lawsuits in Orange County Circuit Court challenging the 2024 ad valorem property tax assessments on some of its most recognizable real estate holdings in Central Florida—including its flagship theme parks, high-end resorts, water parks, parking infrastructure, and even its administrative offices.

The suits, filed in December 2024, name Orange County Property Appraiser Amy Mercado, Tax Collector Scott Randolph, and Florida Department of Revenue Executive Director Jim Zingale as defendants. At the heart of the dispute is Disney’s contention that Mercado’s office grossly overvalued numerous properties—sometimes by hundreds of millions of dollars—and included impermissible intangible property in its assessments.


What Properties Are Disney Challenging?

Disney’s complaints span a wide array of its most valuable properties. The company is contesting the valuations of:

  • All four theme parks (Magic Kingdom, Epcot, Hollywood Studios, and Animal Kingdom)

  • Multiple resort hotels, including Grand Floridian, Yacht & Beach Club, Contemporary, Coronado Springs, and others

  • Water parks (Blizzard Beach, Typhoon Lagoon)

  • Transportation and parking facilities

  • Administrative campuses

  • Specialty locations such as the Wedding Pavilion and Fantasia Gardens Mini-Golf

The total just value assigned across all 12 lawsuits exceeds $4 billion, though Disney is not challenging every single parcel it owns—only those it believes were incorrectly assessed.

A detailed summary of the contested properties and their 2024 valuations appears below:

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Legal Arguments: Overvaluation and Intangible Property

In each complaint, Disney makes several consistent legal claims:

  • Overassessment: Disney alleges the just value assigned to its properties exceeds market value, violating Article VII, Section 4 of the Florida Constitution, which requires property be assessed at just value (i.e., fair market value).

  • Improper Appraisal Methods: The company says the Property Appraiser failed to comply with Section 193.011, Florida Statutes, which lays out factors property appraisers must consider when determining value—including cost, income, and sales comparison approaches.

  • Inclusion of Intangibles: In many complaints, Disney argues the assessments improperly included the value of intangible property—like brand reputation, goodwill, or internal business operations—which are not taxable under Florida law.

Disney also seeks a full reassessment using proper appraisal practices, and it has paid all taxes under protest, as required by Section 194.171, Florida Statutes.


Example Cases

Here are some of the largest individual assessments being challenged:

  • Epcot

    • Just Value: $738.6 million

    • Assessed Value: $713.6 million

  • Hollywood Studios

    • Just Value: $592.7 million

    • Assessed Value: $583.2 million

  • Magic Kingdom

    • Just Value: $577.3 million

    • Assessed Value: $565.3 million

  • Coronado Springs Resort

    • Just Value: $385.1 million

    • Assessed Value: $317.9 million

  • Yacht & Beach Club Resort

    • Just Value: $432.2 million

    • Assessed Value: $355.6 million

Disney is also contesting values for support properties like the MK Bus Drop/Boat Docks ($20.7 million) and the Epcot Wellness Center ($4.8 million).


Why It Matters

These lawsuits could shape how Florida’s property tax laws are interpreted when applied to entertainment properties, resorts, and theme parks, which often involve complex combinations of land, buildings, and business value. The inclusion of intangibles—like branding or synergy between park elements—has long been a legal gray area in assessments of theme park properties nationwide.

The challenges also come amid heightened political tensions between Disney and Florida officials. While these lawsuits are grounded in valuation law, they reflect a broader atmosphere of scrutiny and defense of corporate interests.


What’s Next?

All 12 cases are pending before the Ninth Judicial Circuit Court in Orange County, and Disney is seeking judicial orders to reset the valuations and require new tax bills to be issued.

If successful, these cases could force the Property Appraiser to issue refunds or credits for millions in overpaid taxes. And they may set new precedent for how Florida assesses the value of its largest and most iconic tourism assets.

© 2025 Jeanette Moffa. All Rights Reserved.
 

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Jeanette Moffa Florida Tax Lawyer

Jeanette Moffa, Esq.

(954) 800-4138
[email protected]

Jeanette Moffa is a Partner in the Fort Lauderdale office of Moffa, Sutton, & Donnini. She focuses her practice in Florida state and local tax. Jeanette provides SALT planning and consulting as part of her practice, addressing issues such as nexus and taxability, including exemptions, inclusions, and exclusions of transactions from the tax base. In addition, she handles tax controversy, working with state and local agencies in resolution of assessment and refund cases. She also litigates state and local tax and administrative law issues.

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