Untitled Texas Attorney General Opinion

NEY GENERAL. EXAS PRICE DANIEL ATTORNEYGENERAL March 22, 1948~ Hon. Lee Nowlin, Opinion No. V-523. County Attorney, Hale Coun%y, Re: Validity of tax assess- Plainvhw, *Texas * ments not acted on by the Board of Bqualiza- tion, Dear Sir: We refer to your letter of January 199 1948, in Which you ask: . “Does a county have a legal remedy for the colleceion of taxes where the Commis- sioners’ Court failed to sit as a Board of Equalization.*’ . *. As we construe your question, you request an. * . . opinion as to whether tax assessments are valid if the Colamissioners Court of Male County failed to convene . ai9 a Board of Equalization and act on the assessment lists and books as provided in Artfcle 7206, V.C,S. We are. informed that your Inquiry has reference to assess- mrnts for the years 1945, 1946, and 1947. As refle,cted by the Hale County tax rolls for said years in the office of the State Comptroller, the Assessor and Collector of Taxes placed his oath thereon as provided in Article 7222, V, C, S.; and the Commis- sioners’ Court of Hale County, sitting as a Board of Equalization, placed its cert iffcat e of approval there-. on,, in which it is certified that safd Board examfned the assessments 9 corrected the valuations, and examined the rolls and books made up from approved assessments, and found the property was assessed at its true and full value. Such, certificates are signed by the County Judge and all of the four County Commissfoners of Hale County. The office of Assessor and Collector of Taxes is” created by Section 14 of Article VIII of the State Constitution in Which it is provided that ‘I0 ., 0 such Assessor and Collector of Taxes shall uerform all the @ties with respect to sssessine arouertv for the pur- pose of taxation and of collectfn% taxes as may be pre- scribed by the Legislature,” Hon. Lee Aowlfn - Page 2 (V-523) Articles 718.3-7205 and 7209, 7210, 7211, V.C.S., prsscrlbe the powers and duties of the Assessor and Col- lector of Taxes which include every act pertaining to list- ing property for taxation. Article 7211 authorizes the Assessor and Collec- tor to fix values and provides for appeals by the property owner to the Board of Equalization. The pertinent part of that article reads, in parts “Hereafter when any person, firm or cor- poration renders his, their or its property in this State for taxation to any tax assessor, and makes oath as to the kind, character, qual- ity and quantity of such property, and the said officer accentine said rendition from such D e r - son. firm or coruoration of such urouertv is satisfied that it is correctly and prouerly valued accordinn to the reasonable cash market value of such prouertv on the market at the tine of its rendition, he shall list the same ccordfnzly: but, if the assessor is satisffed that the value is below the reasonable cash market value of such prouerty, he shall at once aace on said rendition ovnosite each wiece of , property so rendered an amount eaual to the rea- sonable cash market value of such arooertv at the time of its rendition, and if such property shall be ,found to have no market value by such offfcer, then at such sum as said offis shall deem the real or intrfnsic value of the proper- ty; and if the uerson-lfstinz such orouertv or the owner thereof is not satisfied with the val- ue olaced on the aroperty bv the assessor. he shal_lgmr a and if desiring so to do make oath before the assessor that t& ‘valuation so fixed by said officer on said proo- ertv is excessive; such officer to furnish such rendition, together with his valuatfon thereon and the oath of such person, firm or officer of any corporation, if anv such oath has been made, to the commissioners” court of the county in which said rendition was made, which court shall hear evidence and determine the true value of such property on January First ., 0 0 .,” Hon. Lee Nowlin - Page 3 (V-523) Article 7222, V. C. S., requires the tax as- sessor to swear that his tax rolls or books are correct, and Article 7223 requires that said officer deliver such lists and statements of property received by him to the Board of Equalization, alphabetically arranged. Commissioners’ Courts, sitting as Boards of Equalization, may ascertain and equalize valuations of property listed for taxation. Articles 7206 and 7218, provide that such Board shall meet on the second Monday in May of each year or as soon thereafter as practica- ble before the first day of June, and receive all lists or books of the assessor and see that every person has rendered his property at a fair market value, correct errors, equalize values and return the lists to the as- sessor, who shall proceed to prepare his tax rolls. Opinion No. O-6708 by a former Attorney Gener- al construes as directory the specification in said ar- ticles of the time when such Boards of Equalization shall meet. A copy of that opinion is enclosed for your in- format ion. Article 7224 provides that the Board of Equal- ization shall examine the rolls or assessment books and make corrections. It reads: “After the board of equalization shall have examined the rolls or assessment books and made all corrections, if any be neces- sary, the assessor shall send one copy Of each to the Comptroller, one copy of each to the collector of his county? and he shall file the other copies in the county clerk’s office until the next assessment, when the assessor shall have the right to withdraw them and use as provided in this title. Id,” Article 7225, V.C.S,, provides that ” 0 e . 0 should his rolls or books, when presented for approval to the c*mmiss&oPers’ courr, prove to be imperfect or erroneous, the court shall have the same corrected or perfected, either by the assessor or some other person than the assessor of taxes, e 0 *I’ Article 7253, R,S., 1925, provides that When. any tax collector shall have received the assessment Hon. Lee Noilin - Page 4 (V-523) rolls or books of the county, he shall receipt to the commissioners' court for the same; and said rolls or books shall be full and sufficient authority for said collector to receive and collect the taxes therein levied." Haynes v. State, 99 S. W, 405 (Error refused) involved an assessment of unrendered real estate in which the list was not presented to the Board of Equal- ization. The completed tax roll was sworn to by the assessor and was examined and approved by the Commis- sioners' Court sitting as a Board of Equalization. The Court said, in part: 'Were the assessments for the years 1900 and 1901 void by reason of the failure of the assessor to list the property for those years and present such lists to the commissioners' court for examination, correction, and appro- val? The defendant offered to show, and x was agreed that if oermitted he could show, that, for the years 1900 and 1901, the proper- ty was not listed by the tax assessor and that no listing of the same was submitted to the commissionersP court sftting as a Board of eaualizatfon. But that the lot was placed up- on the assessorPs block books? which books were never inspected or approved by said board, and then entered upon the tax rolls, and that said tax rolls were submitted to the comm%s- sioners" court sittfng as a board of equaliza- tion for examination, correction, and approval, The court susta&e~an exceat&n to this evi- pence0 The appellant cornplaIns of this action 0 0 D The tax rolls for 1900 and 1901 were pre- sented to, and were examfned and approved by, the commissioners" court sitting as a board of equalization, The aarticular omission com- glained of was the failure of the tax assess- or to list the uroaerte -resent the list to the board for aaorova&. 'Did thfs omission render the assessment for the years named void? . 0 a . "In the case of State v. Carr (MO, Sup,) 77 S. W. 5439 it was held by the Supreme Court of Missouri, construing the tax laws of that State, that an omission to lfst the property Hon. Lee Nowlin - Page 5 (V-523) was not one of the essentials of the law gov- erning the assessment of property for taxa- tion; that such urovision was merely direc- torv and not mandatory and a failure of the assessor to make out t;e list did not vitiate the assessment. In this state a substantial compliance with the statute is treated as suf- ficient to fix a lien for taxes. State v. Farmer, 94 Tex. 235. 59 S.W. 541. It was the duty of the owner-of~the lot to list it for taxation. This dutv he failed to werform It then became the dutv of the ass ssor to list and assess the lot. He failed io list it but it was assessed. It is not denied th& the property was subject to taxation. It was situated in Dallas county, and was liable for taxation in that county, The tax assessor had full jurisdiction over the property, It is not alleged that the valuation placed up- on the property by the assessor, and which the board of equalization approved, was not its true taxable value, It is not denied that the tax assessed against the lot is its proper share of taxes for the years named, Appellant fails to show that he has been In- jured by the failure of the assessor to list the lot, We are of the opinion that the pro- vision in the statute imposing the duty on the assessor to list the property is dfrec- w, and that, in order for the taxpayer to take advantage of such failure, he must show that he has suffered-Lthe omfssfon. State v. Carr. - ~~~ suura, Cftv of Rockland vO Ulmer, supra, O O At the end of the roil was a prop- er certificate of the assessor, as required by the statute, showing, among other things, 'that the rolls to which this is attached contains a correct and full lfst of the real and personal property subject to taxation in Dallas count~$~ etc. This certificate was sworn to by the assessor and the rolls were examined and approved by the board of equal- ization D O O There was no error in exclud- ing the evidence." (Emphasfs added) We are of the opfnfon that failure of the Com- missionerst Court to convene as a Board of Equalfzation . Hon. Lee Nowlin - Page 6 (V-523) does not affect the validity of tax assessments if the completed tax roll is sworn to by the tax assessor and examined and approved by the Commissioners' Court, sit- ting as a Board of Equalization.after completion. We are also of the opinion that the usual procedure is a- vailable to enforce payment of the taxes shown on such approved tax rolls, SUMMARY Tax rolls and books prepared by and sworn~to by the Assessor and Collector as being correct which are subsequently exam- ined, corrected, and approved by the Com- missioners' Court sitting as a Board of Equalization, are valid, notwithstanding failure of the CommissionersD Court to convene as a Board of Equalization as pro- vided in Article 7206 V. C. S. Yours very truly, ATTORNEY GENERALOF TEXAS WTW:wb " W, 'I;, W%iliams Encl. Asststant ATTORNEYGENERAL