Untitled Texas Attorney General Opinion

Honorable Davis Bailey Oplnlon No. WW-421 County Attorney Panola County Re: Whether or not County Carthage, Texas Assessor and Collector of Taxes may lawfully collect taxes, penalty and interest from true owner of property when property has been as- seased in name of Dear Mr. Bailey: deceased former owner. We quote from your request for an opinion a8 follows: "Prior to 1947, Mrs. H. T. Dwyer owned and rendered for taxes 50 aores of land in the Elizabeth Lewis Survey, Abstract No. 385, Panola County, Texas; and Mrs. Dwyer died intestate; and the Tax Assessor of Panola County, Texas, without knowing that fact, continued to assess this property to her, and in her name, through 1957. In that ssme year, 1947, the heirs of Mrs. Dwyer sold the property to A. G. Cassity and F. H. Markey, who never rendered the proper- ty for taxes. In 1954, Markey aold his Interest to Cassity, and recently, Casslty sold the land to L. F. Wedgeworth, Sr. The Tax Assessor- Collector advised that the present owner offers to pay the taxes, but refuses to pay the penalty and interest. Although said land has been ren- dered by the Assessor-Collectorin the former owner’s name, the tax rolls carrying such asseas- ments have been approved through all of the years by the Commissioners'Court; and I also under- stand that during all of the years, said proper- ty taxes were not paid, said property has been entered on the delinquent roll, and such delln- quent roll has likewise been approved by the Commlsslonera~Court. It seems that Mr. Wedge- worth offers to pay the taxes on the supplemen- tal roll, or on the unrendered roll, but does not desire to pay the penalty and Interest ac- crued from the last payment of taxes in about Honorable Davis Bailey, page 2 (WW-421) l947. Mr. Wedgeworth c~onfendsthat the assees- ment against Mrs. H. T. Dwyer is illegal, because she did not own any property in the Elizabeth Lewis Survey during the year from 1947 through 1957. "QUESTION: Whether or not the Aesesaor and Collector of Taxes may lawfully collect penalty and interest from the present owner, L. F. Wedgeworth, from 1947, when the last taxes were paid, for all of the delinquentyears up to date." PROCEDURE FOR RENDITION AND ASSESSMENT All property not exempt from taxation ,whichis owned or held on January 1 must be rendered for assessment between January 1 and April 30 of each year. krticle 7151, V.A.C.S. While it is contemplatedthat voluntary renditions of prop- erty are to be made, there are detailed provisions which require the assessor to call at the office, place of busl- ness, or residence of each owner for the pu ose of aecur- ing a list of taxable property. Articles 71 2 9, 7191, V.A.C.S. The assessor Is further required to take the initiative and prepare a list of all property which Is not rendered to him and assess It for taxation in the neme of the owner, or, if appropriate,In name "unknown." Articles 7193, 7205, 7208, V.W.C.S. The asaessor is to be furnished abstracts of all lands in his cou&y by the Land Office and is required to list for taxation all land so shown to be within the county. Articles 7194-7202, V.W.Z.S. ERRONEOUS ASSESSMENT Article 7171, V.A.C.S., provides that "All real prop- erty subject to taxation shall be assessed to the ownera thereof in the manner herein provided; but no assessment of real property shall be considered illegal by reason of the same not being listed or assessed in the name of the owner or owners thereof." The case of Victory v. State, 158 S.W. 2d 760 (Tex. sup.ct., 1942), held that nn erroneous listing of property in the name of the predecessor in title did not Invalidate the assessment. The case of Young, et al. v. City of Marshall, 199 S.W. 1180 (Tex. Clv. App., 1918, no writ history) is directly analagous to the situationunder con- sideration. In this case suit was brought by the City of Marshall against Margaret Wright for collection of real property taxes for the years lgo6-1glo. The evidence dls- closed that Mrs. Wright had died In 1902, and that the Honorable Davis Bailey, page 3 (WW-421) property had continued to be assessed in her name. The city amended its petition to inalude the heirs of Mrs. Wright and those who had purahased the property from suoh heirs; the city also amended to claim taxes for the years 1906 to 1915. As to the olalm for taxes not barred by a four-year statute of limitationsimposed by the Marshall City Charter, the Court of Civil Appeals upheld the judgment of the trial court awarding the city recovery for taxes, penalties, Interests and attorneys' fees, with forealosure of the tax lien. The judgment was made a charge upon the property alone; no personal judgment was rendered against the defendants. The aourt, in disoussing the assessment, said: the undlaputed evidence shows that tke'pGo;ertywas assessed in the name of Margaret Wright, who died in 1902. It is con- tended that by reason of that faat the assess- ments were invalid and will not etipporta suit for recovery of taxes. Artiale 7527 (now Artiale 7171) of the Revised Civil Statutes provides thatr *All real property subject to taxation shall be assessed to the owners thereof in the manner herein provided; but no assessment of real property shall be consideredIllegal by reason of the same not being listed or assessed in the name of the owner or owners thereof.' 1, under 'the,statuteabove referred to, e&h if'the'rewas az'error in listing the prop- erty in the name of a person who was not the owner, that fact alone Is not sufficientto vitiate the assessment. Taber v. State, 38 Tex. Civ. App. 235, 85 S.W. 835. There is no con- tention that the descriptionotherwise given of the land in the assessmentIs Incorrect or Insufficient." PENALTIES AND INTERESTS Article 7326, V.A.C.S., providea for the institution of suits for collection of taxes, penalties, Interests, and costs. Article 7336, V.A.C.S., details what such penalties shall be and provides in part: "Penalties, interests, and costs aacrued against any land, lots, and/or property need not be entered by the Assessor and Collector . Honorable Davis Bailey, page 4 (WW-421) of Taxes on said list, but In each and eve&-y instance all such penalties, Intereat and costs shall.be.and,remaina.statutorychar e with the same forae and-effeut as if entere -%I on said list, and the Assessor and Collector It Is clear, therefore, that once taxes become delln- quent, penalties and Interest become and constitutepart of the charge against the property. The Tax Assessor and Collector has no authority to release or remit any portion of the penalties and/or Interest so owing. This authority is even expressly denied the legislature. Arti- cle 3, e 55, Vernon's Annotated Texas Constitution. FAILURE TO RENDER PROPERTY The applicationof the rule that an erroneous assess- ment does not render the assessment Illegal under Artl- cle 7171, V.A.C.S., is not limited to cases where the property was rendered for taxation. No distinctionIs made in situationswhere the true owner rendered the property and where no rendition was made, Starnes v. Bledsoe, 27.5 S.W. 2d 826 (Tex. Clv. App., 1953, Ref. N.R.E.) on motion forrehear%; Young v. City of Marshall, supra.-m6'- assessi% made in the case being treated was valid though the property was not rendered. PERSONAL JUDGMENT AGAINST TRUE OWNER OF PROPERTY No personal judgment can be given against a taxpayer for delinquent taxes on property prior to the time he pur- chased such property unless he expressly assumes those taxes. Henson v. City of Corpus Chrlstl, 258 S.W. 2d 343 (9?;9?c1~i;-v2~sEL;9:35 refused); Starnes v. Bledsoe, supra; . The property is, however, subject to foreclosureAf the lien for taxes, penalties, Interests, and costs in the hands of the subsequentpurchaser. Young v. Cfty of Marshall, aupra; Starnes v. Bledsoe, supra; Henson v. City of Corpus Chrleti, supra. See also Victory v. State, 158 S.W. 26 700 (Tex. Sup. Ct., 1942), The present owner of the property in question will not be personally liable for the taxes, penalties or interesta except as such taxes, penalties or Interest accrued during his ownership of the property. Honorable Davis Bailey, page 5 (WW-421) SUMMARY- -..,. The Assessor and Collector of Taxes may charge all taxes, penalties and Interest against the prop- erty In question in the hands of the present owner. The fact that the property was erroneouslyassessed in the name of the predecessor in title does not vitiate the assessment; this rule Is applicable even where the property was not rendered for taxation. No personal judgment may be returned against the present owner for taxes delinquent prior to the time he purchased such property unless he expressly assumes those taxes; but a tax lien for all.past due taxes, penalties and interest may be foreclosed against the property. Any personal judgment will have to run against the person who owned the property at the time the taxes became delinquent,and the penalties and Interest accrued. Yours very truly, WILL WILSON Attorney General of Texas JNP:db APPROVED: OPINION COMMITTEE Geo. P. Blackburn, Chairman J. Mark McLaughlin Harris Toler Riley Fletcher REVIEWED FOR THE ATTORNEY GENERAL BY: W. V. Geppert