Untitled Texas Attorney General Opinion

B-355 Hon. E. F. Campbell Opinion No, V-194 County Attorney Fisher County Re: The authority of the Commis- Robg, Texas sioners' Court, sitting as a Board of Equalization, to con- c slder an assessment on Its own motion and without the Assessor’s request or suggestion, in re- gard to raising valuations. Dear Mr n Campbell: In your letter of April 9, 1947 you request the opinion of this department upon the following question, con- cretely stated in your letter as follows: "When the Tax Assessor for the County, assesses real estate in the regular way and the land owner signs it and swears to it as provided in Article 7211 Vernon Civil Statutes and the assessor accepts lt as mad,e by the land owner, does the Commissioners Court sftting as a board of equalization have a right to take this up on their own motion without any suggestion, notation, re- quest or complaint of any kind from the Assessor and after due notlce to the land holder raise or lower the rendition as to value especially to raise the value?" As a preface to our opinion we point out briefly the constitutional and statutory provisfons pertaining to the Tax Assessor and the Commlssloners’ Court, (Board of Equalization) 0 Suffice it to say that the Office of Tax Assessor Fs a constitu- tional office and Ls provided for by Article VIII, Section 18 of the Constitution, end now combined with the office of Tax Collec- tor by the Constitution as amended November 8, 1932. Therefore, by the terms of Article 718la V,C,S. the terms are used lnter- changeably, and refer to the one office of Assessor and Collec- tor of taxes. Notwithstanding the consolfdation of the two offices there still remains certain statutory duties and func- tions, separate and apart and attached to each respective office, as existed at the tfme of the consolidation, Ther,efore, TOP the purpose of this opinion we shall Hon. E. F. Campbell, page 2, v-194 first confine ours,elves to the duties imposed by statute upon the Tax Assessor O Article 7211 V.C.S * provides: “Hereafter when any person, firm or corpora- tion renders his, their or its property in thfs L?.ta$e for taxation to any tax assessor, and makes oath as to the’kind, character, quality and quanttty of such property, and the sald officer accepting said rendition from such person, firm or corporation of such property is satisfied that ft is correctly and properly valued according to the reasonable cash market value of such property on the market at the time of Its rendition, he shall list the same accordingly; but, if the asses- sor 1s satisfied that the value Is below the rea- sonable cash market value of such property, he shall at once place on said rendltfon opposite each piece of property so rendered an amount eq- ual to the reasonable cash market value of such property at the time of Its rendition, and if such property shall be found to have no market value by such officer, then at such sum as said officer shall deem the real or intrinsic value of the prop- erty; and ff .the person listing such property or the owner thereof is not satisfied with the value placed on the property by the assessor, h,e shall so notify the assessor, and if desiring so to do to make oath before the assessor that the valuation so fixed by said officer on said property Is ex- cessive; sueh officer to furnish such rendition, together with his valuation thereon and the oath of such person, firm or officer OP any corporation, if any such oath has been made, to the commissioners’ court. of the County in which said rendition was made, which court shall hear evldenoe and determine the ~true value of such property on January 1 19 (here give yeas for whioh assessment is madej as- Is herein provided; such officer or oourts shall take Into consideration what 5eid property could have been sold for any time withln six months next beiore the lat day of January of the geap ?OP which the property fs rendered.” In addition to Article 7211 ‘quoted above the following provisions direct the Assessor to’.transmit ‘to the Commissioners’ Court (Board of Equalization) assessments of rendered and unren- dered pPopert$: “‘Article 7218 Hon. E. F. Campbell, page 3, v-194 "The assessor of taxes shall submit all the lists of property rendered to him prior to the first Monday in June to the board of equallzatlon of his County on the first Monday In June or aa soon there- after as practicable, for their Inspection, approval, correction or equallzatlon a O D 6 -" "Article 7206 It0 0 0 (IThe assessors of taxes shall furnish said board on the first Monday in Hay of each year, or as soon thereafter as practicable, a certified list of names of all persona who either refuse to swear or to qualify or to have algn%d the oath re- quired by law, tog&her withtie asaeasment of aaid person's property made by him through other infor- mation; and said board shall examine, equalize and correct assessments so made by the assessor, and when so revised, ecjuallzed and corrected, the same shall be approvsd. "Article 7217 "The assessor of taxes shall furnish the board of equalization on the first Monday in June of each year, or as .soon theresfter aa practicable, a’cer- tiffed list of names of all persona who either re- fused to swear or qualify or to sign the oath as prescribed in this title; also a list of the names of those persons who refused to rendera list of taxable proper%y as required by this title a a .,'I The foregoing statutory provlslons cover generally the duties imposed upon the Tax Assessor in racelvlng the rendi- tion of property owners at the value set by them In making vol- untary renditions of their property for the purpose of taxation and changes made in said renditions by the Tax Assessor as to value and the transmission of such renditfons, whether changed by him OP not, to the Commissioners ) Court (Board of Equalization) for the purpose of equalizing and correetfng the values shown by the rolls. . When he has transmitted the renditions to the Commis- sioners' Court for fts official action, he has completed ,a11 that is required of him until the~Commissfon%rs' Court ha8 acted upon the same as the Board of Bqualfzation. We pass next to the constitutional and statutory duties of the CommfssfonersV Court as a Board of Equallzatlon~ The Com- missioners' Court is a constitutional COUPE provided for by Bon, B. F. Campbell, page 4, v-194 Article V, Section 1, of the Constltutlon which 1s aa follows: "The judicial power of this state shall be vested In one Supreme Court, in Courts of Civil Appeals, In a Court of Criminal Appeals, In D&strict Courts, in County Courts, in Commissioneps Court&, in Courts of Justices of the Peace, and in such . other courta as may be provided by law," (Emphasis supplied) The jurisdiction of the Commissioners' Court 1s'dePined in the'latter part of Section 18 of Article V of the Constitution as follows: "The county commissioners so chosen, with the county judge, as presiding officer, shall compose the County Commissioners Ccurt, which shall exercise such powers and jurisdiction over all $ountg businesp, aa is conferred by,thls Constitution and the laws of the State OF as ma be hereafter prescribed." (Emphasis supplied 7 There is, however, an express llmitatlon upon the juris- diction thus conferred upon the Commissioners' Court, that is, it mast be "county business", Tke Constitution has further expressly conferred upon the Legislature the power to provide, as nearly as may be, the valuation of all property subject to or rendered for taxation, This is provided for by A~ticls VIII, Section 18 of the Constf- tution as follows~ "The Legislature shall provide for equalizing, as near as may be, the valuation of all property subject to or rendered for taxation, (the County Commissioner's Court to constitute a board of equalization); and may also provide for the clasa- ification of all lands with reference to their value in the several counties." This brings us to yc~r concrete problem of whether or no% the Commiss loners I Cour% (Board of Equalization) may act upon Its own motion in equalizing value without Its jurlsdlctlon in this regard being first invoked by the Tax Assessor. The answer to this questlon 1s in %he affirm&tive~ We dlscuaa briefly our reasona for this conclusion. As above noted, Sectlm 18 of Article VIII of the Constltulon requires %he Legislature to "provide for equalizing as near as may be, the valuation of all property subject to or rendered for taxation," Pursuant to this constitutional mandate the Legislature has by the Wactwnt of . Hon. E. F. Campbell, page 5, v-194 Articles 7206 and 7212 V.C.S. provided for equalizing the valua- tion of all property subject to or rendered for taxation. The terms of Article 7206 are: “Each commlssloners court shall convene and sit as a board of equalization on the second Monday in May of each year, or as soon thereafter as prac- ticable before the first day of June, to receive all the assessment lists or books of the assessors of their counties for Inspection, correction or equal- ization and approval I ” Article 7212 v.c,s, provides: “The 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 1s not in accordance with the laws of the State, to ln- crease or diminish the same and to affix a proper valuation thereto, as provided for in the preceding article; ‘O o m . O” When the Legislature said In Article 7206, V.C.S.; !‘shall examine, equalize and correct assesments so made by the assessor, and when so revised, equalized and corrected, the same shall be approved” and sald l.n Article 7212, V.C.S. the “Board of equalization shall have power, and It Is made their offlclal 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 the State, to increase or diminish ,the same and to affix a proper valuation thereto,” It dealt with such matters unquestionably as “county business” appropriately entrusted to the Commlsslonsrs I Court acting as a Board of Equal- lzatlon, In the exercise of this quasi judicial function the Commlsslonersl Court (Board of ISquallzatlon) may do so upon its own initiative without a suggestion from the Tax Assessor. This view has been confirmed In the ,Case of Brundett et al vs. Lucas 194 9,W. ~614 (Ct. of Civ. App. San Antonio) e !lbe following is stated: “We conclude that the act of 1879 which be- came article 5120, R-9. 1895, and article 4715 Rd. 1879 were both designed to give the board of equal- ization the power to equalize assessments In al,1 cases, regardless of whether the assessor or any one else made complaint, and this appears to have been the construction placed thereon by the Suprem Court . Hon. E. F. Campbell, page 6, v-194 when it cited both provisions in support of its statement with reference to the change made. In 1907 said article 4715, then No. 5124, was amended so that the first portlon thereof reads as fol- lows : “‘The boards of equalization ,shall have power) and it is made their official duty, to supervlse the assessment of their respective counties, and, if satisflea that the valuation of any property is not in accordance with the laws of the state, to increase or diminish the same and to affix a proper valuation thereto, as pro- vided for in article 7569 of this chapter . 0 0f “And thus’ amended, it now appears as article 7570 R.S. 1911. As l,t now reads, It it111 con- fers ample power to equalize without complaint, even though the words ‘without complaint from any one’ were omitted; but If such omission could be given the effect contended for by appellee, nev- ertheless article 7564 gives the board full power to equalize and makes it the duty of the board to do so, regardless of whether any;complalnt has been made by t,he assessor or any one else. This article received renewed legislative spproval in 1909, therefore cannot be said to be affected by the repeal clause &the act of 1907 had there been a conflict between the two acts, We conclude that the judgment cannot be sustained on the theory that, as the assessor made no complaint, the action of the boeti was not authorized.” We point out that whet was formtirly Article 5124 dls- cussed in this case is now Article 7212 and as will be observed Is in identical language, but as it read before amended It specifically said “without complaint from any one” - Bowever s as was saLd in Brundett et al vs, Iucas supra, t,he power still re- mains to act “without’ complaint from any one under Article 7206 - 7212, The phrase without complaint from any one” was iii the amendment simply eliminated as surplusage. Article 7212 “shall have power etc.” Shall have power to do what? i%cle 7212 gives the answer as follows: 11 to auperyfse the essesment of thelr,iespectfve counties, and, If satisfied that the veluatlon of any property 1s not in accord- ance with the laws of the State, to increase OP zp;im;zh the same and lo affix a proper valuatfon 9 a 0 0 0 0 0 D . Hon. IL F. Campbell, Page 7, v-194 A more recent case to the same effect is Wright vs. State (Ct. of Civ. App. Amarillo) 80 S.W. (26) 1015 from which we quote as follows: "The action of the equalization board In fixing values IS judicial In Its nature, and they may flx such values based upon matters wlthln their own knowledge a e e The general rule is that equalization boards may act upon their own judgment of what la equal and just, and, In the absence of fraud, their determination cannot be challenged if It appears that they have previously Inspected the properties with the view of deter- mlnlng values 0 s D 0 *" It does not follow, however, that the Commissioners Crrurt (Board of Equalization) may increase the values in the ex- ercise of its Judicial functions wlthout giving the taxpayer notice and an opportunity to be heard, for such notice Is a necessary prerequisite to its jurisdiction, and without It there would be a lack of "due pro 89s". Highland Park Independent School District of Dallas Cfil nty, et al vs. Republican Insurance Company, 80 S.W. (2d) 1053. Hoefllng vs. San Antonio 39 S.W. 918 (Supreme Court.) In this latter case the court said: The board has no power to increase that v&e'(referring to the value fixed by the property owner in his rendltlon) without glvin notice to the owner 0 0 0 *" (Parenthesis ours k It follows from the foregoing that we are of the oplnion that the Commissioners I Court (Board of Equallzatlon) has the power and authority to raise or lower valuation of property for taxation without the same being lnltlated by the Tax Assessor, but if the valuation is to be raised notice mst be given to the taxpayer of the Board's intention to raise such valuatFon and give him an opportunity to be heard. SUMMARY The Commissioners' Court (Board of Equali- zation) has the power to raise property valua- tion for taxation without its jurisdiction belng first invoked by the Tax Assessor. It may act upon its own inltlative. If the valuation 1s increased, however, notice mst be given to the taxpayer. Article 7206, V.C.S., Article 7212, V.C.S.; Brundett et al vise Lucas, 194 S.W. 613, State vs. Wright, 80 S.W. (26) 1015. Hon. E, F. Campbell, page 8, v-194 Yours very truly, ATTORNEYGENERAL OF TEXAS By: s/L. P. Lollar L. P. Lollar Assistant APPRUVED MAY10, 1947 s/Price Daniel ATTORNEY G-