Untitled Texas Attorney General Opinion

-. .-.. ._ Hon. William Schneider, Jr. opinion No. V-1399 county Attorney Gillespie County Re: Taxability of Fredericksburg, I-Texas leasehold es- -, tate of tenant ~. of an independ- ‘-~-ent school dis- Dear Sir: tri.ct . You have requested the opinion of this office as to the taxability of the leasehold es- tate -of a tenant of the Fredericksburg Independent -------+hool-District., ~The certified copy of the lease “contract which you enclosed with your’request shows that the lease is for a primary term of fifty years. Article 7173, V.C.S., provides: “Property held under a lease for a term of ‘three years or more, or held un- der a contract for the purchase thereof, belonging to this State, or that is ex- empt by law from taxation in the hands of the owner thereof, shall be considered -for all the purposes of taxation, as the -, ,_- ------property of the person so holding the same except as otherwise specially pro- vide d by law. . . .e Your specific question is stated as follows: “In construing Article 7173, is the '\ estate of the tenantacquired under the lease contract with Fredericksburg Inde: ‘, pendent School District subject to rendl- tion and taxation as a leasehold estate?” While the Legislature could subject lease- hold Interests in nonexempt property to taxation if It so chose, under the present scheme of taxation in force in this State the owner of the freehold of nonexempt property is liable for taxes on the entire value of the I 86 Hone William Schneider, Jr., page 2 (v-1399) property, even though it is under lease.’ T D q 71 Tex. 192 9 S.W. 99 (1888) r”~x.h$~096 Taxation iec:66 leasehold inEerest in the propeity in question to be taxable, it must come within the provisions of Ar- title 7173. If this property is “exemp~t by law from taxation in the hands of the owner’ thereofe and if the Legislature has the power to tax a leasehold in- terest in the property it would follow that the es- tate of the tenant wouI d be taxable. It may be noted that the courts construe Article 7173 as author- izing the assessment of the property against the les- see not%t the value of the freehold but only at the -value of the leasehold’ estate. Dauphertv v. Thomuson, sunra. The property involved is a block of land located In the town of Fredericksburg. Originally designated and dedicated by the German Immigration .Company as public property for educational purposes, .this property has been under the control of the ~Fred- ericksburg Independent School District since its in- corporation in 1885. The school di.strictls title to the property was confirmed by a district court judg- .ment rendered in 1920. The lease contract shows that the RederL&s- burg Independent School District has leased the land to an individual for a primary term of fifty years, iktyles~see agreeing to erect a building on the prop- . The lessee is to pay a stipulased monthly rental for a period of fifty years. hereafter, the rental is to be determined by a rental committee ap- pointed in a manner set out in ~the contract, the ten- ant having the privilege of surrendering the lease if the rental is not satisfactory to him. You state in your letter that the lessee has erected an office building on the premises. It is evident that the school district is now using the property In question to produce revenue. The facts which have been submitted to us .suggest that the school board has abandoned any plans which may have been formulated in the past to use the prop- erty as a school site; however, the present intention of the board in this regard presents a fact question w hi c h. this office does not have the authority to decide. 1us0, we are not here passing on the liability Hon. William Schneider, Jr., page 3 (V-1399) 8%‘~’ of the lessee for taxes on the improvements which he has placed on the land, since that question likewise depends upon the intention and agreement of the parties respecting title to the improve- ments. Edwards v. Thannisch, 254 S.W. 523 (Tex. ~. CIV.’ A p,. 1923); Ropers V. Fort Worth Poultrv % gg @. , 1i 5 S.W.2d 165 (Tex. Civ. App. 1945). If t?tle to the building has presently vested’in the school district, the building would be taxable in the same way as the land. On the other hand, if it remains the property of the lessee during the existence of Fk,“,i;;se,, he’would be liable ‘as owner for taxes . Independent school districts are empowered b y s t atute to receive conveyances of property “for the benefit of the public schools,” and their power of ownership Is not limited to property ac- tually used as school sites. Art. 2756, V.C.S.; Adams v. Miles, 35 S.W.2d 123 (Tex. Comm. App. 1931); Hushes v. Gladewater County Line Indenendent School &g&., 124 Tex. 190, 76 S.W.2d 471 (1934). Cf. Art. 2773a, V.C.S. It is clear, therefore, that the own- ership and use of this property by the school dis- trict for a purpose other than as a school e..t;$; authorized by the statutes of this State. opinion we shall assume that the revenue derived” from property belonging to a school district becomes a part of the local funds of the district and must be used for school purposes in accordance with the provisions of Article 2827 V.C.S. In any event, you have informed us that the rent from this property Is being deposited to the local funds of the district and is being expended under the provisions of Article - 28.27. The Constitution of Texas contains two pro- visions relating to the exemption of public property from taxation. Section 9 of Article XI provides: _ “The property of counties, cities and towns, owned and held only for pub- lic purposes,, such as public uildings and the sites therefor. WQ Fire en- gines and the furniture thereof, and all property used, or intended for extin- guishing fires, public grounds and all other property devoted exclusively to ‘88 Bon. William Schneider, Jr., page 4 (V-1399) , the use and benefit of the public shall be exempt from forced sale and from taxation, provided, nothing herein shall prevent the enforcement of the vendors lien, the mechanics or'builders lien, or other liens now stisting." ,This provision of the Constitution is self- executing and accords an absolute exemption to prop- erty coming within its terms. A. & M. Consolidateq v. Citv of Brvan 143 Tex. In m & Trust co., 144 Tex. 326, 190 S.W.2d 48 (1945), it was held that the Lower Colorado River Authority was a governmental agency serving a public purpose and that its property was exemut from taxation under Section 9 of Article XI. On the authority of that case and State v. City of San Antonio, 147 Tex. 1, 209 S.W.2d 756 (1948) this .-office held in Att*y Gen. Op. v-1308 (195l)th&llthe exemption accorded ~by this constitutional~provision extends to the property of any governmental agency which is devoted exclusively to the public use" and that the property of an independent school district .~..nsed as a public school site was thereby exempt from all forms of taxation, including spe,cial assessments for improvements. In pauffhertv v. Thompson, m, the Supreme Court held that the Legislature does not have the power to impose a tax upon a leasehold estate in property which is exempt under this constitutional provision, whether imposed on the owner or the lessee. This deci- --“sion has been followed in Davis v. Rurnett, 77 Tex. 3, 13 S.W. 61 (X390), and & Cattl C v. hoard, a0 Tex. 489, It n”,ceZI sarilp follows that if Article XI, Section 9 exempts the property in question from taxation in the hands of the school district, the leasehold estate likewise is exempt. paushertu v. Thomnsog involved county school lands alloted to co ties under Article VII, Section 6 of the Constitution. 'lp Whilettze &&sin thepresentinquiry JJ Under a constitutional amendment adopted in 1926, agricultural and grazing lands which counties own as school lands are now taxable, except for State purposes to the same extent as lands privately owned. Tex. Cons c ., Art. VII, Sec. 6a. Hon. William Schneider, Jr., page 5 (V-1399). may appear at first blush to be analogous to those in the pauehertv case, we have reached the conclu- sion that the character of county school lands held under grant from the State .is different from that of lands held by an independent school dis- trict for the production of revenue., In that case the court observed that even in the absence of the provision in Article XI, Section 9, "looking to the policy which this state has steadily pursued in granting lands to counties for educational purposes, it could not veil be he1 that the legislature in- tended by Article 4691 2R.S. 1879, now Art. 7173, R.C.S. 1929 to impose a tax on school lands owned by counties even when leased; for taxes levied on such lands, while owned by counties, whether imposed on the counties or their lessee would but diminish 'the rental value of such lands, which it is not rea- sonable to suppose was intended when the sole purpose for which such liberal donations were made was to furnish the counties with a school fund." While independent school districts are em- powered to o+.n land for the purpose of producing in- come, this method of raising revenue is extraneous to the established means of support of their schools. .Independent school districts in the main derive their support from the State Available School Fund ar.4 sth- er appropriations of State moneys, from the County Available School Fund (income from the permanent fund created under Article VII, Section 6 of the Conctitu--/ tion), and from local taxatioil. It is only in iso- lated and sporadic instances that school districts de- rive even a small part of their revenue from income on property which they own. The considerations of pol- icy in the exemption of county school lands do not support a similar exemption for income-producing pro,-- erty of independent school districts. We conclude that Daunhertv v. Thomcson is not compelling authority for holding that the property in question is exempt from taxation. Consequently, we must make an independ- ent determination of whether this property is lldevoted exclusively to the use and benefit of the public.1t The second constitutional provision relating to exemption of public property is Section 2 of Article / VIII, Constitution of Texas, which provides, in part: '1. * . the legislature may, by general law's, exempt from taxation public property -- Iion. IEl.liam Schneid~er, Jr., page ,6 0I-139) used for public pnrpose~s; actual plac.es or ,@ religious worship, also any prop- erty owned by a church or'by a strictly religious society for ~th.sexclusive 'use as a dwelling'place for th~e ministry of such church or religious soc~iety, Andy which yields no 'revenue whatever to such church or religious society; provided that such exemption shall not extend to more property than is reasonably neces- sary for a dwelling place and .in no event more thau one acre of laud; places of burial not held for private or corporate profit; all buildings~used exclusively and owned by persons or associations of persons for school purposes and the neces- sary furniture of all schools and property used exclusively and reasonably necessary In conducting any association engaged in promoting the religious, educational and -_--~_~-physical development of-~boys, girls,-young men or young women operating under a State or National organization of like character; also the endowment funds of such institn- .tions of learning and religion not nsea .w~ith a view to profit; and when the same are invested in bonds or mortgages, or ?.n land or other property which has be-en artd shall hereafter be bought in by such in- stitutions under foreclosure sales made to satisfy or protect such bonds or mortgages, that such exemption of such land and prop- erty shall continue only for two years af- ~.,~,-__~-.t.er~thepurchase of the same at such sale by such institutions and no longer, and institutions of purely public Charity; and all laws exempting property from taxation other than the property above mentioned shall be null and void." Thissection of the Constitution does not Itself exempt any property from taxation, but author- zL;L; the Legislature to exempt certain types of prop- Acting under this authorization, the Legisla- ture-enacted Article 7150, V.C.S., which contains the . Bon. William Schneider, Jr., page 7 (V-1399) following provision:2 "The following property shall be exempt from taxation, .to-Wit: . . . "4. All property, whether real or personal, belonging exclusively to -. this State, or any political subdivi- . sion thereof, or the United States, . . . I, Article 7150 provides for an exemption of 'I&, property belonging exclusively to this State, '-"or any political subdivision thereof." An independ- ent school district is a political subdivision of the State. Kins~s Estate v. School Trustees of Wil- lacv Count :333 S.W.2a 783 (Tex. civ. App. 1930 error ref. If the exemption in subdivision 2, of Article 7150 could be given effect according to its terms, the property in question would be exempt from -'?e&ation inthe handsof~-the owner. However, the property exempt under Section 9 of Article XI is prop- : erty of counties, cities and towns owned and held snf-v for oublic ourooses and other property devoted x lusi Iv to the u na benefit of the oubliq and "-Ehz proikty which tg ~tegislature may exempt under Se;tiF 2 of Article VIII.is public property B ed fez pu 1 uuroos es. Although the attempted exemption in 2J Article 7150 also contains a provision relat- ing to,exemption of property used for school purposes. Assuming that this provision includes property of an ~:~--------~--independent school district, the property in question clearly does not satisfy the conditions for exemption set .out in then Constitution and Article 7150. 2/ While school districts are in a sense State agen- cies in that they are created for the purpose of carry- ing out a function of the State government, their status in relation to the State government is expressed in the following language from Hatcher v. State, 125 Tex. 84, 81 S.W.2d 499, 500 (1935): llSchool districts, whether independent districts or common school districts, are not primarily agencies of the state, but they are local public cor;oorations of the same general character as munlci al -~~oorations." Ghis opinion is not to be understood as passing on the &ability of property owned by the State ItasU which is not used for a public purpose. . Hon. William Schnsider, Jr., page 8 (V-1399) 92 Article 7150 is broader than authorized, the provi- sion is operative to the extent of the Legislature’s power, that is, to exempt such property when used for public pur oses. City of Abilene State 113 S.W.2d 631, 63% (Tex. Civ. App. 1937, &?or di&u.). The authority to exempt property under ‘Sec- tion 2 of Article VIII is to be exercised by the Leg- islature, and the Legislature has the power, within constitutional restrictions, to prescribe the condi- tions upon which an exemption is accorded. Since the Legislature could either grant or withhold the exemp- tion imthe first place, it might also provide that the-.exemption would not extend to property which~ an exempt owner has leased to another person. It follows that if property is exempt from taxation under Article 7150, V.C.S., solely by virtue of the authorization in Article VIII, Section 2 of the Constitution, the lease- hold is properly taxable under Article 7173. These two constitutional provisions, as well as the decisions construing them, make it clear that there are some types of publicly owned property which are not and cannot be exempt from taxation. We therefore have three possible situations in respect to the property under consideration: (1) if it is exempt by virtue of Article XI, Section 9 of &/ Article VIII, Section 1, Constitution of Texas, rovides that “all property in this State, whether owned t y natural.. persons or corporations, other than muni- ciphi, shall be taxed in proportion to its va1ue.l’ In Daugherty vD Thomusou, m, the court stated that Section 1 of Article VIII l’does not require property belonging to municipal corporations to be taxed.” How- ever, Section 2 of.Article VIII, after setting out the types of property which may be exempt, provides that “all laws exempting property from taxation other than the property above mentioned shall be null and void.” It would appear that only such property as is exempt by the Constitution itself or as may be exempt by the Legislature under .Section 2 of Article VIII can be re- lieved from taxation. This is the only construction under which we can explain the numerous cases Involving municipally owned property where the court found it necessary to decide whether the property was being used for a public purpose. . .~, Hon. William Schneider, Jr., page 9 (V-1399) 93 the Constitution, the leasehold estate is also ex" empt; (2) if the property is exempt in the hands of the school district by virtue of Article 7150, V.C.S., enacted purmant to the authorization contained in' Section 2 of Article VIII, the leasehold is taxable under Article 71733 (3) if the property is not being "devoted exclusively to the use and benefit of the public" or is not being "used for public purposes," it is not exempt in the hands of the school district and Article, 7173 has no application. We have not found where the courts of this State have ever,been called upon'to consider the pre- cise question here involved. Indeed, not often has it been necessary for the courts to decide whether public property which has been held to be exempt came under Article XI, Section 9 of the Constitution or un- the Constitution and example, A. & M. Con- Dist. v. Citv of BrYan suma.> We may state some generalizations, however: which are pertinent to a solution of this question. In the first place, the exemption under either of these provisions is not limited to property which is used for governmental purposes. A. & M. Consolidateg Independent School Dist. v. CitY of ~BrYau, Suora. Secondly, the fact that the property produces revenue does not of.itself prevent its being exempt, if the use to which the DroDertY is DUt meets the reauired test of being a public use. 8. & 14. Consolidated m- dooendent School Dist. v. Citv of Brvaq, suura: Lower Colorado River Authoritv v. Chemical Bank & Trust Co., SUDraj Citv of Abilene v. State, suDra* State V. City of Houstoq, 140,S.W.2d 277 (Tex. Civ. App. 1940, er- ror ref.). y In Lower Colorado River Authority v. Ch mi Cal B&.Trust.,suDra, the court repeated,d&um in Daunhertv v. Thomosog to the effect that Article VIII, Section 2 applied to "property held in private owner- ship but used for purposes which give to it a public character." Under this view the Legislature would be powerless to tax the leasehold estate in any publicly owned property which is exempt in the hands of the owner. The property involved in that case was actually ._ being used in the performance of the functions for which the public agency was created and accordingly came within the exemption of property "devoted exclu- sively to the use and benefit of the public" under Sec- tion 9 of Article XI. 94‘ Hon. William Schneider, Jr., page 10 (V-1399) Upon reviewing all the cases which have been decided under the Constituti6n and statutes of this State, we find that publicly owned property which has been held to be exempt from taxation may be classified as ~follows: 1. Property used by the public or actual- ly being put to use exclusive,ly in carrying out a public function performed under the powers of a gov- ernmental agency, whether the function b,e govern- mental or proprietary. In this category we find such I cases as Lower Colorado River Authority v. Chemical Citv of Brvaq, B. such a use, although used in part for other purposes, w~ould also be exempt. See City of Abilene v. State,. 'Butma. Conceivably, this latter exemption might in some situations come under Section 9,of Article XI and in others under Section 2 of Article VIII, but it is not necessary here to consider the exact ~bounda- ries of the exemption under each of the constitutional provisions in such instances. 2. Property which is a part of or stands in the place of a public fund. Cases illustr&tive of this classification include Dauahertv v. T mm Sh mard 144 Tex. %l ?$& =' ,"i other caies holding tdt prop- 'delinquent tax foreclosures is ex- empt . Cf. State v. Cl y ous man v. William, 8:~ T~kH421~of$ ~b0~). %;s;xemption likewise results from Section 9 of Arti- . 3. Property which is intended for actual use in carrying out a public function where there has not been an abandonment of the intended use, although iz act,ual use for that purpose is temporarily suspend- Cases of this nature include Citv of Abilene V. Stite, suura; State v. City of Beaumont, 161 S.W.2d WTex. Civ. App. 1942). This exemption is by virtue of Article VIII, Section 2 of the Constitution and AI?- title 7150 of the Revised Civil Statutes. -... Bon. William Schneider, Jr., page 11 (V-1399) 95 It is obvious that the property leased'by the Fredericksburg Independent School District for '. commercial development does not come within,the first class of exempt property. Nor do we think it comes within the second class. All the cases in this class which have held such property to be exempt involve funds raised by taxes or other public money or, as in the ~case of Daugherty v. Thomnson, property which is itself made a part of a fund created by law. The fact that the income from a school district's proper- tyheld under a permissive ownership becomes a part of a fund used for the support of the public schools after~it is ctillected is not sufficient to make the 'property itself a part of the fund or to make it rep- resent any part of the fund. As noted above, the courts of this State 'have never been'called upbn to decide the precise ques- tion presented in your r,equest. Opinions of.the Attor- -~-'-----'--..ingney General's results. Office have reached apparently conflict- .-Opinion O-4459 (1942) .held that property devised to a county, the income from which was to be used for the supqort of a county hospital, was exempt .while Opinion o-4285 (1942) held that property devise B _ --,,,to a city, .the income from which was to be used for the support and improvement of the city's public parks, was not exempt. In Opinion V-447 (1947), rendered during the present administration , it was held that land orig- inally acquired by a county- for use as a poor farm rnfas not exempt whare the intended use had been abandoned., although the income from~the property went into the county's charity fund. --~~~---The prevailing view in other jurisdictions is that prdperty which is being held and used solely for the production of income is not exempt from taxation un- der constitutional and statutory provisions similar to those in force in this State, even though the income is See Notes, 3 A. L. R. 1439; iq49; 101 A.L.B. 787; 129 A.L.R. 480. After considering all the authorities herein discussed, we have reached the conclusion that property , . . .* / 94% ,/ which an independent school dist2ictmms mily&r the purpose of producing~income*i:s not ?be%frrgused for a public purpose within the:maaning:ofthe COP stitution and is notexempt from -taxationin-the hands of the owner, Consequently,the Leasehold interest under a lease :fora t:ermmf thre-e:yaarsror more would not be taxable to zthelessee.. :fIowever, if the property is ~h&ldfor the eventu&l :purpose-of being used as a part,of the school-facilities, {even though it is being leased te@porar'ily, :it.Tsexempt from taxation in the .handsof the school district under the provisions ofArticle VIII, Section2 -of the Consti,tution and Article 7130 of the.Revised Civil Statutes, but it is not exemptunder Article XI, Section 9 of the Constitution. Ihthis -event, the value of the .leaseholdinterest,zhder:a:lease for a term of three years or.more:istaxable :to;the ,.y lessee under Article 7173. -4, ..--.~-:.--~-- ---++operty which ah 'inde~peniient school district owns and holds only for the :pu.r- pose of producing income is :not:exempt from taxation in the hands .ofthe .owner., and the 'leaseholdinterestunder .alease ~~~-.~--for a term of three years :or.moreis :not ., caxable to the Ylessee. Property~whichis held for the eventual pur,poseof being used as a part of the school:facilities~, though leased temporarily is exempt from taxation in the hands of 4he owner; and the value of the leasehold estate .mder a lease for a term of three years or more _ ....-$L7ex.bteSto the lessee under .Article 9 * . . APPROVEO: %ur.s xe~y *LiUIy, W. V. Geppert Taxation Division E. Jacobson ReviewingAssistaut Charles D. i