Justia Tax Law Opinion Summaries

In two consolidated property tax disputes, Oncor Electric Delivery Company NTU, LLC sought a multimillion-dollar reduction in the total values of certain electric transmission lines in the 2019 certified appraisal rolls for the Wilbarger County Appraisal District and Mills Central Appraisal District. Oncor’s predecessor had agreed to the lines’ value in each county to settle its protests of the Districts’ initial appraised values, but Oncor now contends that these agreements are void due to mutual mistake.Previously, Oncor filed unsuccessful motions for correction of the appraisal rolls with each County Appraisal Review Board (ARB) and then sued in district court in Wilbarger and Mills Counties. The trial and appellate courts below provided conflicting answers on whether questions regarding the effect of a Section 1.111(e) agreement—such as its validity and scope—are relevant to a trial court’s subject-matter jurisdiction over a suit for judicial review under Section 42.01 of the Tax Code.The Supreme Court of Texas held that the resolution of such questions does not implicate jurisdiction and remanded the cases to the trial courts for further proceedings. The court did not reach the merits of the parties’ disputes about whether Oncor has identified errors eligible for correction under Sections 25.25(c) or (d) of the Tax Code, whether any such errors fall within the scope of the parties’ Section 1.111(e) settlement agreements, and whether the doctrine of mutual mistake is an available defense to such agreements. View "MILLS CENTRAL APPRAISAL DISTRICT v. ONCOR ELECTRIC DELIVERY COMPANY NTU LLC" on Justia Law

The case revolves around a tax appraisal dispute involving Texas Disposal Systems Landfill, Inc. (the Landfill) and Travis Central Appraisal District (the District). The Landfill owns 344 acres of land in Travis County, which it operates as a landfill. In 2019, the District appraised the market value of the landfill at $21,714,939. The Landfill protested this amount under the Tax Code provision requiring equal and uniform taxation but did not claim that the District’s appraised value was higher than the market value of the property. The appraisal review board reduced the appraised value of the subject property by nearly ninety percent. The District appealed to the trial court, claiming that the board erred in concluding that the District’s appraised value was not equal and uniform when compared with similarly situated properties. The District also claimed that the board’s appraised value was lower than the subject property’s true market value.The trial court granted the Landfill’s plea to the jurisdiction, arguing that the challenge it made before the appraisal review board was an equal-and-uniform challenge, not one based on market value. Thus, the trial court lacked jurisdiction to consider market value. However, the court of appeals reversed this decision, holding that a trial court’s review of an appraisal review board’s decision is not confined to the grounds the taxpayer asserted before the board.The Supreme Court of Texas affirmed the court of appeals' judgment. The court concluded that the Tax Code limits judicial review to conducting a de novo trial of the taxpayer’s protest. In deciding the taxpayer’s protest in this case, the trial court is to determine the equal and uniform appraised value for the property subject to taxation. This limit, though mandatory, is not jurisdictional. The case was remanded to the trial court for further proceedings. View "TEXAS DISPOSAL SYSTEMS LANDFILL, INC. v. TRAVIS CENTRAL APPRAISAL DISTRICT" on Justia Law

The case revolves around J-W Power Company (J-W Power), a company that leases, sells, and services natural gas compressors used in oil and gas operations. The company maintains these compressors in many counties across Texas and often leases them to customers in neighboring counties. The case specifically involves the taxation of compressors maintained in Ector County that were leased to customers in Sterling and Irion Counties. J-W Power filed motions to correct the appraisal rolls under section 25.25(c) of the Tax Code, arguing that the appraisal rolls included “property that does not exist in the form or at the location described in the appraisal roll.” The Appraisal Review Boards (ARBs) in both counties denied the motions, leading to the current lawsuits.Previously, the district court granted summary judgment to the appraisal districts, arguing among other things that res judicata barred the section 25.25(c) motions because those motions involved the same subject matter as the prior Chapter 41 protests. The court of appeals affirmed this decision, holding that res judicata barred J-W Power’s section 25.25(c) motions, which raised “nearly verbatim” claims as compared to its prior Chapter 41 protests.However, the Supreme Court of Texas disagreed with the lower courts' decisions. The Supreme Court held that section 25.25(l) of the Tax Code preserved J-W Power’s right to file a section 25.25(c) motion notwithstanding its prior Chapter 41 protests. The court interpreted the phrase “regardless of whether” in section 25.25(l) to mean that a property owner can file a section 25.25(c) motion regardless of whether there was a prior Chapter 41 protest related to the value of the property. Therefore, the Supreme Court reversed the judgments of the court of appeals and remanded the cases for further proceedings. View "J-W POWER COMPANY v. IRION COUNTY APPRAISAL DISTRICT" on Justia Law

The case involves Yvondia Johnson, a 100% disabled U.S. Air Force veteran, who applied for a residence homestead tax exemption for her principal residence in Converse, Texas. The Bexar Appraisal District denied her application because her husband, also a 100% disabled U.S. military veteran from whom she is separated, claimed the same exemption for his principal residence in San Antonio, Texas.The trial court granted summary judgment for the appraisal district, arguing that Ms. Johnson was ineligible for the exemption because her husband claimed the same exemption on a different home they jointly owned. Ms. Johnson appealed, and the court of appeals reversed the decision, ruling in her favor.The Supreme Court of Texas affirmed the judgment of the court of appeals. The court held that the Tax Code bestows the exemption on each individual 100% disabled veteran who meets the express statutory requirements without regard to whether the veteran’s spouse also claims the exemption on a separate residence homestead. The court found that the plain text of Section 11.131(b) of the Tax Code unambiguously states that a 100% disabled veteran is entitled to a tax exemption for his or her residence homestead. The court concluded that Ms. Johnson satisfies the express, unambiguous requirements of Section 11.131(b) and therefore is entitled to the benefit of the tax exemption for 100% disabled veterans. View "BEXAR APPRAISAL DISTRICT v. JOHNSON" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the order of the trial court dismissing Duncan House Charitable Corporation's application for a charitable organization exemption, holding that the court of appeals erred in concluding that Duncan's failure to timely apply for later exemption precluded it from receiving that exemption even if it ultimately qualified for an earlier exemption.For the 2017 tax year, Duncan applied for a charitable tax exemption covering its fifty percent ownership interest in a Houston historic home. The appraisal district denied the exemption, and the review board denied Duncan's ensuing protest. Duncan filed for judicial review. Thereafter, although Duncan House never applied for the charitable exemption for the 2018 tax year, it protested the district's 2018 appraisal on the grounds that the district court to apply the charitable exemption. The review board denied the protest. Duncan then amended its trial court petition to challenge the denial of the 2018 exemption. The trial court dismissed the 2018 claim for want of jurisdiction, and the court of appeals affirmed. The Supreme Court reversed, holding that the court of appeals erred in holding that Duncan's failure to timely apply for the 2018 exemption precluded it from receiving that exemption even if it ultimately qualified for the 2017 exemption. View "Duncan House Charitable Corp. v. Harris County Appraisal District" on Justia Law

The Supreme Court held that no statute expressly authorizes a school district to retain a lawyer on a contingent-fee basis to prosecute litigation designed to increase the appraised value of property so as to generate more tax receipts for the school district and that authority for such an arrangement cannot be implied from a school district's express authority to bring litigation regarding appraisals.Iraan-Sheffield Independent School District employed attorney D. Brent Lemon on a contingent-fee basis to pursue claims designed to increase the appraised value of property so as to generate more tax receipts. After the Appraisal Review Board denied the challenge the school district appealed. The district court granted Defendants' Rule 12 motion challenging Lemon's authority to represent the school district and then dismissed the case with prejudice. The court of appeals reversed, concluding that Tex. Tax Code 6.30(c) authorized the contingent-fee arrangement. The Supreme Court affirmed on different grounds and remanded the case, holding that the district court (1) correctly granted Defendants' Rule 12 motion; but (2) erred in dismissing the case with prejudice. View "Pecos County Appraisal District v. Iraan-Sheffield Independent School District" on Justia Law

The Supreme Court denied Relators' petition for a writ of mandamus and their accompanying motion for temporary relief against the Comptroller, holding that Relators failed to establish that they were entitled to relief.At issue were Relators timely applications for participation in the Texas Economic Development Act, which allows allows school districts to offer ten years of considerable property-tax incentives. Under Tex. Tax Code 313.007, access to the statutory program expires on December 31, 2022. The Comptroller asserted that the a lack of available resources meant that December 31 would pass before he could complete the necessary evaluation for Relators' applications. Relators sought temporary and mandamus relief. The Supreme Court denied relief, holding that Relators did not have a judicially-enforceable right to compel the Comptroller to act on their applications or to extend the statutory deadline to account for the processing delays. View "In re Stetson Renewable Holdings, LLC" on Justia Law

The Supreme Court granted Petitioner's petition for review of the decision of the court of appeals affirming the decision of the trial court granting the City of Austin's plea to the jurisdiction and dismissing this case brought by Plaintiff alleging that the City provided taxpayer money to abortion-assistance organizations in violation of Texas law, holding that the case must be remanded.The trial court granted the City's plea to the jurisdiction without explaining its reasons and dismissed with prejudice Petitioner's claim that the City's budget violated Texas law and dismissed with prejudice Petitioner's claim that the City's 2019 budget violated the Gift Clause. The court of appeals affirmed, relying on the Supreme Court's holding in Roe to conclude that Petitioner's claim could not proceed. Petitioner petitioned for review. After briefing was complete, the United States Supreme Court issued its opinion in Dobbs v. Jackson Women's Health Organization, 142 S. Ct. 2228 (2022). The Supreme Court granted Petitioner's petition for review without regard to the merits and vacated the judgments below, holding that, because Dobbs overruled Roe, remand was required for consideration of the effect this change in the law and any intervening factual developments on Petitioner's claims. View "Zimmerman v. City of Austin" on Justia Law

The Supreme Court held that the Comptroller of Public Accounts of the State of Texas properly taxed an insurer based on premiums it received from sales of "stop-loss" policies under Texas Insurance Code Chapters 222 and 257, holding that the Comptroller properly assessed the taxes at issue.Blue Cross Blue Shield sought a refund of its 2012 premium and maintenance taxes collected from its stop-loss policies, arguing that the policies did not cover risks on "individuals or groups" under Chapter 222. The trial court agreed and ruled for Blue Cross. The court of appeals affirmed. The Supreme Court reversed, holding (1) the premiums Blue Cross collected on its stop-loss policies were subject to taxation under Chapter 222; and (2) because Blue Cross collected these premiums under its authority to write health insurance, they were subject to Chapter 257's maintenance tax. View "Hegar v. Health Care Service Corp." on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing this case asserting that the city of Houston's house mayor and city council members acted ultra vires in spending tax revenue in Fiscal Year 2020 on anything other than the drainage fund, holding that the taxpayers had standing to assert their claims and sufficiently pleaded ultra vires acts.Plaintiffs, two Houston taxpayers, brought this case alleging that City officials misallocated tax revenue because the City Charter requires a certain amount of tax revenue to be allocated to a fund exclusively for drainage and street maintenance and that the officials acted ultra vires in spending the revenue on anything else. The officials filed a plea to the jurisdiction asserting governmental immunity. The trial court denied the plea. The court of appeals reversed, concluding that the taxpayers lacked standing. The Supreme Court reversed, holding (1) Plaintiffs alleged an illegal expenditure sufficient to support taxpayer standing; and (2) the City officials were not entitled to dismissal of Plaintiffs' ultra vires claim on governmental immunity grounds at this time. View "Jones v. Turner" on Justia Law