Untitled Texas Attorney General Opinion

EA~~ORNEY GENEMAL OF TEXAS I)ear Sir: Opinion No. O-4931 Re: Whether man living in one county may claim his ranch in another county az his homestead. Your request for an opinion on the above question reads as follows: "A man is employed and maintains a residence in '4' county. He owns no real estate in 'A' county. He owns a ranch in 'B' county. Although he has never maintained his principal residence on the ranch, he and his wife, on various occasions have spent several days and nights on the 'B' county property. !'Ishall thank you to advise me whethwor not, in your opinion, this msn Is entitled to a homestead exemption from State taxes on the 'B' county real estate." The situation presented in your letter is not such that it may be said az a matter of law that the ranch either is or is not this man's homestead. Whether or not certain property constitutes the homestead of a family is largely de- termined by the intention of the hesd of the family, together with the particular circumstances which may tend to establish or discredit such intention. For this reason we cannot give a categorical answer to your question. The essential elements of a homestead and the rules applicable thereto are set out in our opinions Numbers o-1638 and o-4164, copies of which are attached hereto. By way of supplementing these opinion3 we shall discuss a few~additional authorities which we believe to be peculiarly applicable to your question. In Taylor Feed Pen Company v. Taylor National Bank, (ct. of Civ. Appeals, 1915) 181 3.W. 534, (Judgment and modified on other grounds by the Commission of Appeals, 215 S. W. 850) Honorable Tom A. Craven, page 2 O-4931 the court announced the following rule at page 540: "While actual residence is not necessary under all circumstances to fix the homestead character upon land, a mere intention to occupy land some time in the future as a homestead, unaccompanied by any act clearly evidencing such intention, is not sufficient to attach to such land the homestead character.' (Authorities cited) In Parker v. Cook, (Court of Civil Appeals, 1909) 122 S.W. 419, the facts were quite similar to those presented in your question. Mr. Cook owned a 61. acre farm in Red River County, which was adequately equipped to serve as a home for himself and family, which he designated as his homestead. He and his family never actually occupied this property but in- stead he moved to Fort Worth, where he followed his trade as a carpenter. ,It appearing that Mr. Cook was unable to make a living at his trade of carpenter while living on the Red River County farm, the Court held that such farm could not conzti- tute his homestead, being unfit a,zto him to meet the require- ments of a home. Said the court: II . . . The tract of land was a farm; but Cook was a carpenter, not a farmer. He Intended to occu- py the farm whenever conditions changed so that he could go there and make a living for his family and money to pay his debts. Such a time might never come. There was no evidence to show that there was any good reason for expecting it in the near future. To sus- tain the homestead claim in this caze would be carrg- ing the effect of intention alone beyond the limits fixed by any adjudicated case we have examined. . ." In First Coleman National Bank of Coleman v. Childz, Eastland Court of Civil Appeals, 1938) 113 S. W. (2d) 602, writ refused) the court declared: "Under the circumstances of this case, the mortgagor, or Child3 and his wife are estopped to assert the homestead claim to the 200 acres in question, regardless of the fact that the husband, after moving from the farm to the city property, made certain uses of the farm for raising stock and agricultural products, both of which were consumed in the maintenance of his family while residing in the city property. In other words, the use of rural land by a city or.town resident does not in itself support homestead claims therein. Alexander v. Wil- son, zupra; Roberts v. Cawthorn, 26 Tex. Civ. App. 477, 63 S. W. 332." Eonorable Tom A. Craven, Page 3 0 -4931 In Nunn'z textbook on "Texas Homestead" at page 95, the following prerequisites for the acquisition of a home- stead are laid down: "There is no constitutional or statutory provi- sion directing the manner by which the homestead char- acter is impressed upon lands other than the ztipula- tier,: 'provided, that the zame shall be used for the purposes of a home, or as a place to exercise the call- ing or business of the head of the family.' In the judicial interpretation and application of this pro- vision it has become well settled that the homestead character is impressed upon property: (a) by the actual use and occupancy of the property as a homestead; (b) or by a present intent to so use and occupy the same, coupled with acts of preparation, demonstrating such intent. "Intent, in itself, will not impress the home- stead character upon property, but such intent must be accompanied with a preparation, demonstrating such intent; and the said acts of preparation must be pro- secuted with reasonable diligence to the extent that, within a reasonable time, they will result in the actual use and occupancy, or else it will be deemed that the intent to zo use and occupy has been aban- doned. Ultimate, actual use and occupancy of the prs;:ertgas a homestead is contemplated in all cazes. If the intent be abandoned before the occup5jncybe- gins,,no homestead rights are acquired. . . While the facts submitted in your letter are inadequate to permit us to answer your question as a mattter of law, we believe the foregoing authorities support the following con- clusions which may guide you in the determination of the ques- tion: 1. If the man has never actually maintained his prin- cipal residence at the ranch in "B" county so as to impress it with the character of a homestead, occasional visits of several days are ineffectual to accomplish such a purpose. 2. If the man hss no immediate intention of terminat- i~g his employment in "A" county, and if the ranch in "B" county is not suitably located as a residence while engaged in such emPloymen~tin 'A" county, then the ranch cannot constitute his :homestead. Honorable Tom A. Craven, page 4 0 -4931 Yours very truly ATTORNEY GENERAL OF TEXAS By s/Walter R. Koch Walter R. Koch Assistant WRK:AMM:wc ENCLOSURES APPROVED NOV 13, 1942 s/Gerald C. Mafin ATTORNEY GENERAL OF TEXAS Approved Opinion Committee By s/BWB Chairman