The Petitioners in this case appeal the striking of their challenge to a tax assessment under the sixty-day jurisdictional time limit period provided by law. Petitioners argued that their property should have been classified as exempt government property. The Petitioners argue that challenges to classification of property are not subject to the sixty-day filing period for assessment challenges. The First District Court of Appeal found that the Petitioners' "classification" argument was tantamount to an assessment challenge and agreed with the trial court that it was untimely filed. The Petitioners now seek a reversal of the First District's opinion.