Under Florida tax law, real estate is valued for taxation as it exists each January 1. Taxes based on this valuation do not become due until the next November 1. County governments, meanwhile, must use a fiscal year that begins each October 1. Under this system, property owners can escape taxation on new construction for a period of time that may exceed a year. If improvements are built between October 1 and January 1, they escape taxation until the following October 1 because counties cannot consider them in their budgets. If improvements are built after January 1, they escape taxation until November 1 in the following year. Collier County enacted an ordinance to recoup these lost taxes through a complex formula. The trial court ruled this was an unauthorized tax, and the County appeals