Justia Tax Law Opinion Summaries

Respondents, owners of a vendors lien on each of four tracts of land, sued to have their liens declared superior to petitioner's liens. At issue was whether petitioner's liens were not unenforceable pursuant to section 32.06 of the Texas Tax Code's requirements for transfer. The court held that petitioner's tax liens were not unenforceable when verified copies were recorded in lieu of originals; when the procedure wherein the tax collector made the required certification before a notary, sealed with a notarial seal, in lieu of a seal of his own, complied with section 32.06(d); and when the tax collector's record-keeping and receipts were irrelevant to the enforceability of petitioner's liens.