Untitled Texas Attorney General Opinion

LiUSTIN. TEXAS Hovember 21, 1949 Bonorable Stewart Y. Rollman Criminal Matrict Attorney Fort Worth, Texas opinion Ho. Y-949. Re: Reduotion In valuation of property ae aifecting eligl- bllity of sahool distrlots for Foundation School Fumd grants, and requirementof county-wide%q~llGatiOn mzhool dietritts to report funds derived from school maintenance tex aa county Dear Sirr amilable funds. Your request for an opinizm relates to ellgl- bility of school districts Sor FoundationSchool Fund grmt8 where the value of property baa decreased and the valuation is reduced. It also relates to the accouuta- bllity of county-videequalizationschool districts for funds derived from school aaintenancetax in report+g county available funds under S.3. 116, Aata 51st Leg., B.S., 1949. The questions submittedare: '1. There being no express provision In the Act, and there certainlybeing none in the paragraphsreferred to, to prohibit can a school district reduce the valu- ire; oa amy property or propertlea In said district and still be eligible for aid under said Act? ‘2. Are these fund8 (oounty-wideequal- ixatloa funds) to be reported to the State Auditor under said Act, particularlyuuder SubdivisIon (b), Paragraph 13, State Audit- or's Form Ro. BA-2-6495" With respect to your first questian: State and county assessed valuation of the taxable property of districts Is used in the formula Hon. Stewart Y. Hellmen, page 2 (W4S) designed for Celculetingthe amount of'local fuuda to be oharged mbool dLatrZat8. Sectifm 5 of Article VI, S.B. 116, Aeta 51st Leg., R.S., 1949 (Found&ion Sahool Pro- gram Act) reads In part% “Mvide the state and county aaaes8sd Val- uaitiori of all property In thQ county subject to school district taxation for the next preceding school year Into the State and county assessed ValPatlafiof the district for the aext p-cod- lng school year, finding the dlatrlct*aper- centage of the county valuation. Multiply the district’spercentage of the county valuation by the amount of funds assigned to all of’the dlatriata in the county. The product shall be the emount of looal funds that the district shell be assigned to raise toward the fineming of its Foundation Sohool Prograa~.~ Said section further provideat "The County Tax Aaaeaaor-Collectorin each county, . . . shell oertify to the State Gem- ~&x~?.I~~of Bdua&tlou e . . the followlag la- "(1) The assessed valuation, on a State and oounty valuation basis, of all property aubjeot to school district taxation in eaoh school diatr.ictor portion of aohool diatriot in such county, and the total aaaeaaed Value- tlon of all property aubjeot to school dla- trict taxatlan in the county; w o -” Section 1, Artfele VIII of'the Conatltuticmof Texas, reeds lp pert% " all property in this State abell be taxei in.proportloato its velue, which hhll be ascertainedas my be provided by . . e l Seation 14, Article VIII of the Conatltutlon of Texas, provides that8 “There shell be eleoted by the quellfled electors of aech county + e D an Assessor and Colleotor of Taxes, . . . end auoh Assessor and Collector of Tax88 shall perform all the Hon. Stewart W. Bellman, page 3 (V-949) duties with respect to assessing property for the purpose o? taxation.. . . .” Article 7174, V.C.S., reads in part: “Each separate parcel of real property shall be valued at its true and full value in money, excluding the value of crops grov- ing or ungathered thereon. . . .” Article 7206, V.C.S., reads in part: “Each ccaamlsaloners court shall convene and sit as a board of equalization on the sec- ond l4ondag in May of each year, OF as soon thereafter a8 practicable before the first day of June, to receive all the assessment lists or books of the assessors of their aountles for inspection, correction or equalization and approval. ’ Uhen property Is rendered for taxation the assessor-collector places the property on the tax rolls if he la satisfied the property is pende~ed at the rea- sonable cash market value. I? he is not so satisfied he enters the reasonable cash market value on the rendl- tion and the party rendering the property may have the true value dete&ed by the county conrmissloners court, if dissatls?led vlth the value fixed by the assesaor- collector. Art. 7211, V.C.S. Article 7212, V.C.S., provides thatr mThe boards of equalization shall have power, and It is made their official duty, to supervise the assessment of their respective counties, and, if satisfied that the valuation of any property Is not in accordance with the laws of this State, to increase or diminish the same and to affix a proper valuation there- to, as provided for in the preceding article; and, vhen any assessor In this State shall have furnished said court vith the rendition as provided for In the preceding article, it shall be the duty of such court to call before It such persons as in Its judgment may knov the market value or true value of such proper- ty, as the case may be, by proper process, who Hon. Stewartu. hellman, page 4 (v-949) shall testify under oath the character, quali- ty and quantity of such property, as vell as the value thereof. Said court, after hearing the evidence, shall fix the value of such property In accordance with the evidence so introduced and as provided for in the preced- ing article; and their action in such case or cases shall be final." Section 5 of Article VI, S.B. 116, supra, fur- ther provides: "I? there has been a marked increase or decrease in the assessed valuation of a school district within a county, and if the County School Board certifies that the use of the county and school district valuations for the PreCeding year in determinIng local fund assignments to the school districts in the county would be Inequitable, and recom- mends a different distribution of the county total than that made by the State Consnission- er of Education, such recommendations, sub- ject to the approval of said Commissioner, shall become and be the lawful local fund as- signments to such districts." hanifestly, the quoted provisions of Senate hill 116 pertaining to valuation of property are in har- mony with general law and the Constitution. Senate Bill 116 does not, in our opinion, seek nor operate to alter, change, or disturb the valuation procedure long estab- lished and in use for purposes of taxation in this State. Clearly, the language, "I? there has been a marked in- crease OP decrease in the assessed valuation of a school district . . .v recognlses that there will be fluctua- tions in the value of property in school districts. Un- der the organic and StatUtWy law, Change in value must be taken into account. Increase OP decrease in assessed valuation may be recognized without affecting eligibili- ty for Foundation School Fund grads by giving effect, in proper oases, to recommendations of the County School Board. The Foundation School Program Act contemplates limitations upon districts with respect to reduction of tax rate: Hon. Stewapt W. Hellman, page 5 (V-949) %o school district shall be eligible to receive foundation school funds authorized herein vhich lovers its total school tax pate within tvo (2) years of the effective date of this Act, I? the reduction of such tax rate would reduce thz local maintanauce tax re- ceipts . . . . Sec. 5, Art. VI, S. B. 116 Acts 51St Leg., B.S., 1949. (emphasis added) However, we do not construe this language as in anyvise applicable to the power to ascertain value for tax purposes as required by the Constitution and laws of this State, since the subject of this provision is rate of tax as distinguished from value of property to which the rate is applied. The Ae%T$%aina no pro- vision of similar import relating to valuation. In- crease OP decvease in valuation would operate to vary the amount of local funds charged to conmcu school dia- trlcts and independent districts using State and county valuations as indicated by the formula quoted above, but eligibility for grants would not be disturbed. It Is apparent, therefore, that valuation of property in school districts may be reduced, when cir- cumstances and evidence determinative of value require, without affecting eligibility of such districts for foundation school fund grants for which they are other- Vise eligible. Uith respect to your second questlont Section 3 of Article VII of the Constitution of Texas provides In part: ” e And the Legislature may authoriee au addl&al ad valorem tax to be levied and collected within all school districts hereto- fore fomned or hereafter formed, for the fur- ther mainteuauce of public free schools, and for the erection and equipment of school build- ings therein; provided that a majority of the qualified property tax-paging voters of the district voting at an electlou to be held for that purpose, shall vote such tax not to ex- ceed in any one year one ($1.00) dollar on the one huudved dollars valuation of the property subject to taxation In such district, . . .* Lou. Stewart W. Bellman, page 6 (V-949) Pursuant to authority of this provision of the Couatitutlou, the Legislature has created a number of counties as county-wide equallaation school districts having the Cotmty Unit System of Mucation. These dia- tricts exeraiae the taxing power conierred upon school districts by suoh provision with. limitations prescribed in the several Aots when voted by a majoflty of the qualified property tax-payi voters of the district. Acts 44th Leg., R.S., 1935, 3 h. 103, p. 284, Art. 27408, V.C.S. ; Acts 45th Leg., B.S., 1937, Ch. 231, p. 454, Art. 2744e, V.C.S.; Acts 45th Leg., R.S., 1937, Ch. 163, p. 315, Art. 27401-2, V.C .S . ; Acta 46th Leteg., R.S., 19391 ;pS Lava, p. 677, Art. 2744e-1, V.C.S.; Acts 46th’ 1939, Sp. Lava, p. 673, Art. 2744e-2, V.C.S.; ;:$$&h’ieg., R.S., 1941, Ch. 95, p. 121, Art. 27401-3, . . .; Acta 47th Leg. R.S., 1941, Ch. 2 3, p. 400, Art. 2740?-4, V.C.S. i Acts 47th Leg., R.S., 19 ;: 1, Ch. 150, p. 218, as aabanded, Acts 50th Leg., R.S., 1947, Ch. 85 p. 145, Art. 2744e3, V.C.S.; Aota 50th Lag., R.S., 1947, Ch. 331, p. 617, Art. 2702-A, V.C.S.; Acts 50th Lag.,, R. S -9 1947, Ch. 399, p. 800, Art. 2740?-5, V.C.S. Sectiou 6 of Article VII of the Constitution of Texas creates the cow&j available fund: " Said lends, and the proceeds thereof; ihen sold, shall be held by said couuties alone as a truat for the benefit of public schools therein; said proceeds to be Invested . . . and the counties shall be responsible for all investments; the inter- est thereon, and other revenue, except the princlipsl shall be available fuud.” Interest derived from investment of the pePma- nent land or trust fund and other Pevenue from such fund, except the p~lnolpal thereof, constitute the couuty available fund; and only the interest thereon leapbe un- ed and expended annually. Art. 2824, V.C.S. Section 5 of Article VII of the Constitution of Texas creates the state available school fund and enumeratea certain sour- ces of Income and revenue for the fund. The Legislature la specifically authoriced to supplement the fund by adding not to exceed l$ annually of the total value of the pePamnent school fuud. Section 6, supra, of this AP- tlcle, contains no provision for adding to or SuppleaIent- lng the county available fuud. Hon. Stewart W. Hellman, page 7 (V-949) Article 2692, V.C .S., provides that the county superintendent shall make pro rata distribution of the state available school fund based on the scholastic cen- sus, and: I( . . . shall at the same time appor- tion the income arising from the county school fund to all the districts, lnclud- ing the independent school districts of the county, making a pro rata distribution as per scholastic census.* Thus, income arising from the county available fund _ _ Is distributed in the same manner and upon the same oasis (scholastic census) as the state available funds apportioned to counties. The only source of income to the county avall- able fund provided In the Constitution is interest and other revenue derived from the county permanent fund. The Legislature has in effect defined other revenue to Include leasing or renting of lands, while proceeds from the sale of timber Is required to be invested as pro- ceeds from the sale of land. Art. 2825, V.C:S. In Simona v. Jackson County 63 Tex. 428 (1885), it Is said hat interest on notes egeouted in part payment of the purchase price of land becomes part of the available fund. But, proceeds from a lease conveying land for min- ing and operating for oil and gas may be said to be per- manent funds as the transaction represents a sale of the minerals in place. Ehlineer v. Clark, 117 Tex. 547, 8 S.W.2d 666 (1928). Article 2827, v.C .S . , enumerates the purposes for which the public free school funds may be expended: (I . . . State and county available funds shall be used exclusively for the payment of teachers’ and superintendentat salaries, fees for taking the scholastic census, and interest on money borrowed on short time to pay salt- &es of teachers and superintendents. . . This article also describes the purposes for vhich local funds may be expended: l local school funds from district taxes, iAt.& fees of pupils not entitled to free tuition, and other local sources may be Hon. Stewart W. Hellman, page 8 (V-549) used for the purposes enumerated for State and county funds and for purchasing appliances and supplies, for the payment of insurance premi- ums, janitors and other employees, for buying school sites, buying, building and repairing and renting school houses, and for other pur- poses necessary in the conduct of the public schools to be determined by the Board of Trus- tees. . . ." Sound reason supports the view that the avail- able fund created by Section 6 of Article VII, supra, is a fund separate and distinct from other funds made avail- able by law under any other provision of the Constitution for the operation, maintenance, and support of the public free schools. Likewise, the available school fund pro- vided in Section 5 of Article VII, supra, is a fund sepa- rate and distinct from other funds made available by law under any other provision of the Constitution. Both are constitutional funds. The sources of income or revenue to each ape particularly described by the Constitution and laws of this State, and the use of each is defined and restricted by legislative declaration. Section 1 of Article VI, S.B. 116; Acts 51st Leg., R.S., 1949, provides that the Foundation School Pro- gram shall be financed by: "a. An equalized local school district effort to the extent hereinafter provided to- ward the support of this program; "b. Mstrlbution of the State and Coun- ty Available School Funds on the basis of the number of scholastics; and 'C. Allooation to each local district a sum of State money appropriated for the pur- poses of this Act sufflclent to finance the remaining costs of the Foundation School PPO- gram in that district computed and determined in accordanoe with the provisions of this Act.' “It is abundantly clear, we think, that the county available fund referred to in the Act and intend- ed by the Legislature is ~the available fund provided in Section 6 of Article VII, supra, end that equalieation funds made available in county-vlde equalization school Hon. Stewart W. Hellman, page 9 (V-949) districts by the levy of a school maintenance tax con- stitute local funds as distinguished from constitutional available funds and may not be included therein. I? the Legislature had intended othervise, it could have easily so declared. County-wide equalization funds are derived from a tax levied by districts exercising the taxing power conferred by the Legislature uuder Section 3 of Article VII, supra, vhile the available fund Is derived from ln- terest and other revenue from public lands OF county per- manent fund. In general, county-wide equalization funds are by law distributed to districts on a per capita bas- is according to the scholastic census for the maintenance and support of the schools of the district. Hove;er, AP- tlcle 27&O?-5, V.C.S., provides for distribution . . . according to the financial needs of said school districts . . . so as to provide a salary of not less than two thousand ($2,000.00) dollars per year to any teacher em- ployed. . . .” With this one exception, use of county- wide equalicatlon funds is unrestricted as to purpose, vhile use of the available fund, as has already been pointed out, Is limited by general statute to particular purposes. The Foundation School Fond created by the Oil- mer-Alkin lava, is an w fund, grants frcnn which are intended to pay professional salaries, transporta- tion and current operating costs other than professional salaries and transportation. It supplements State and county available funds which are also o eratl as seen from Article 2827, V.C.S., v supra. ocal fonds~J funds from district taxes may be used for the erection of mane& imorovements and certain other purposes, in ad qfr tion to those enumerated for State and county funds. Surely, it vas not the intention of the Legis- lature to supplement building funds of dlstriets vlth grants from the Foundation School Fund. As observed, Foundation School Fund grants supplementtheoperating funds. Mstricts that have levied the county-wide equal- ization tax, by vote, would be penalized if Gilmerdikin gPadS were reduced by the amount raised locally by such levies. We see no objection to school districts levying county-wide equalieatlon or other local taxes in addi- tion to taxes levied to raise local funds Charged to such districts by Senate Bill 116 to supplement either operat- ing funds or permsnent improvement funds. Hon. Stewart W. Hellman, page 10 (V-949) - l3veFett Hutchlnson $Hrdb:bh Assistant APPROVED