Untitled Texas Attorney General Opinion

THE ATTOECNEY GENEECAL OF TEXAS The Honorable M. L. Brockette Opinion No. R-798 Commissioner of Education Texas Education Agency Re: Amount of maintenance 201 East Eleventh Street tax which can be levied by Austin, Texas 78701 a particular school district. Dear Dr. Brockette: You have requested otiropinion regarding the"smount of maintenance tax which may be levied by the Hutto Independent School District. We a0 not determine disputed questions of fact, and we assume the.facts you presentare correct. You state that in 1965 the District voted pursuant to then article 2784e, V.T.C.S:, ti,authorize the~annual levy of a school tax at a rate not to exceed $1.50 on each $100.00 valuation of taxable property. ,That tax included a bona tax not to exceed 50& per $100 valuatidn and a maintenance tax not tomexceed the difference between $1.50 ana the 50$or less allocated to the bona tax,. The maintenance tax portion of article 2784e provided: The amount of maintenance tax, together with.the amount of bona tax of any district, shall never exceed One Dollar and Fi'ftyCents ($1.50) on the One Hundred ($100.00) Dollars valuation of taxable property; and if the rate of bona tax, together 'width the rate of maintenance tax voted in the district shall at any time exceed On& ~Dollar and Fifty Cents ($1.50) on the One Hundred ($100.00) Dollars valu+ion, such bona tax shall operate to reduce the maintenancestax to the difference between the rate of the bond tax~.andOne Dollar.and Fifty Cents ($1.50). V.T.C.S. art. 2784e, S 3. p. 3366 The Honorable M. L. Brockette - page 2 (H-7.98) Thus, under article 2784e the bond tax and maintenance tax were interdependent; i.e., if an increase in the bona tax raised the sum of the two above $1.50 per $100 valuation, the main- tenance tax had to be reduced accordingly. In 1969, the Legislature enacted the Texas Education code. The Code established a bond tax and a maintenance tax independent of each other. Education Code, S 20.04. But the new tax structure of the Code was not made applicable to taxes previously authorized. Section 7 of House Bill 534, which enacted the Education Code, provided that th(?repeal of statutes by this act shall not repeal or affect any tax or authority or power heretofore granted by the Legislature under 'which any tax has heretofore been authorized. . . by an election 'held under any act or acts of the legislature.heretofore enacted whether general or special. Acts 1969, '61stLeg., cb. 889 at 3026. Cotiseqtiehtly, even after enactment of the Education Code, the authority of the Hutto Independent School District to issue bonds and to levy taxes was derived from article 2784e. In 1975, however, the District held an election on two propositions: (1) to authorize the school board to levy an annual maintenance tax not to exceed $1.50 per $100 valua- tion, pursuant to section 20.04(d) of the Education Code; and (2) to authorize the issuance of unlimited tax bonds under section'20.04(b)(1). The bond proposition was enacted but the maintenance tax proposition was defeated. As a result of the election, therefore, the District is authorized to levy a bond tax under the Education Code. By the terms of section 20.04(b)(l), such tax must be "sufficient, with- out limit as to rate or amount, to pay the principal of and interest on said bonds." Since the maintenance tax proposal failed of enactment, however, maintenance taxes continue to be subject to the restrictions of section 3 of article 2784e. Indeed, section 20.08 of the Education Code provides: p. 3367 The Honorable M. L. Brockette - page 3 (H-798) . . .a11 maintenance taxes heretofore voted in any school district in accordance with law may be levied and collected in the manner provided by the law in effect at the time such bonds were voted, or issued in the manner provided in this subchapter, to the extent pertinent and applicable, without an additional election. Maintenance taxes levied under article 2784e, however, are tied to the amount of bona tax. Even though the amount of bona tax is, as a result of the 1975 election, required to be unlimited, it is nevertheless our opinion that the amount of maintenance tax plus the amount of bona tax must not exceed $1.50 per $100 valuation so long as the limitations of article 2784e, section 3 are applicable in this district. Thus, in answer to your first question, whenever the rate of bond tax together with the rate of maintenance tax exceeds this amount, the maintenance tax must be reduced to a rate equal to the difference between the total annual bona tax and $1.50. You also ask whether the District may levy a bond tax in excess of SO& per $100 valuation, in light of the $1.50 maintenance-bond tax limitation of article 2784e, section 3. Article 2784e, section 2 previously limited the permissible bond tax to 5Ob per $100 valuation. In the 1975 election, however, the voters approved the bond tax authorized by the Education Code in section 20.04(b)(1). This bond tax is no longer limited to 506 per $100 valuation and, indeed, is required to be "sufficient, without limit - as -. to rate or amount, to pay the principal and interest on saidnz." (Emphasis added). Thus, we conclude that the District is now permitted to levy a bona tax in excess of 5Op!per $100 valuation. D. 3368 The Honorable M. L. Brockette - page 4 (H-798) SUMMARY So long as the Hutto Independent School District derives its authority to levy a maintenance tax from article 2784e, section 3, V.T.C.S., it must, whenever the rate of its bond tax, together with the rate of its maintenance tax, exceeds $1.50 per $100 valuation, reduce the maintenance tax to a rate equal to the difference between the total annual bona fax and $1.50. The District is now permitted to levy ~a bona tax in excess of 5Ob per $100 valuation. Very truly yours, of Texas APPROVED: Opinion Committee jwb p. 3369