Untitled Texas Attorney General Opinion

OFFICE OF THE ATTORNEY GENERAL OF TEXAS AUSTIN Honorable George 3. Sheppml iIokpttoll6r of Publio Aooounts AUElt.LrI, Texas Dear Sii: Ill YOW 16tt6r 40, you advim thqt in 1934 a oertain taxpayer r perty at .lts actual market value, which rend1 duoed by the Board of Equallzatimi. Eovwrer, as el-',iesIn the county for the am year es w6xx-1lntantlon3Uy tixqd at only for alue by the atard of Equalization. Y s to whether or not tho Cocmission mcy now deolare such aFJsesomalt voi to ba mossessod for the year in qu lsad Civil Statutss, in ren- Yalu.3tion Lbercto ," etc. Khl.lo it is untioubtodly ooniezplsted that property shall be ofxossed and taxed u.gon its fail cash mar&t value ht. 8, see. 20, and Art, 8, Sec. 1, State Const., at-a! Art. 7164, ii.C.3.)‘ iS aust bo borne in tinti that Artiole 6, Section Eionorable George Ii. Sheppard, Page 2 the Constitiction of Texas, also requires that Taxation ;L”L be equal and UniforsP, and provides that nisl..l. property . . l &all be taxed fp groportion to its value". Xn Lively vs. N. K. and T. ~?ai.luayCoznw, 120 S.S. 222, by the Supreme Court, ths intang5.bl.oassets of a railroad wera assassed at full value, vheruas 'tie property or individ~uels was assessed at only two thirds of its real value, in accordance vith a deliberately adopted policy. In answer to certified questions, the Supren3 Court held that the trial court had cor- rectly granted an injunction against the collection of taxes on nor% than two thiz-ds of the value of such intangible assets. After observing _that v;hile other property was deliberately assessed at oaly 66 2/3 per cent of itsreal Value, the lntangi- ble assets of ths appellee were assessed at 100 per cent, the court said: *. . . It Is evident that this was a deliberate soheme 69 the part or the officersor Eallas oounty by nirich the assessmnt was tide at the pro?ortioh of its value stated, end there is nothins An ths case to IJdtiuate that there was any tietake on the part or the offioers. It was the delibera:elp adopted policy to so discrizlnate betwee the 6ifferaEt olasses of property in the as6essc;ent for taxation. It is not necessary that the officers fin so disorimlnating should have intendeds~ecificslly to injure the ap- pellee or Ether railroad co4~mi8s. It is sufficient that by their action they Ce::iad the appellee the equal proteotion of the Constitution and lam of the state. The intention vith vhich the acts were done is of no oax3eq2ep3e. Suoh,deliberate action on the part of officers charged vith the ezforcezent of the la-amst be Bald. to ba the aot of the state, and she C appellcc me. aztitledto relief a:;sinst t:ie.eaforce- ment of the exce3sive assensmnt, , . *Counsel for the ap~:ellants objeot ~to the re- &Jction of th6 vslus of app311ee13 gropcrty as assessed by tbc stsse board beca~oe t&at. ,a3sessznt was mdo in cmfmzzity to the Gm3tituticg -gmC !.av3 of the stat6 2inti ms tkrefore valid. I< is clairied that it is not pertissiblo to overturn this valid assess~mt anti to bc.ne the juQ,mnt of the court up- on that v:;S:ch~3 &ado contrary to the 1~:~s and Con- stitution. Thst is it p1nusibl.a >m?osition, and w~3uld ba u2plicablc if the object of t.lis prooai?ding 721 Boaarable i38orge H. Shsppsrd, Page 3 were to enroroe the ri.zhts or the appqlee to a rair valuation of its property. But, aa statted bePore in this opinion, the wow +Ai.iohwas'inflicte% upon the appellee was noi,in re.qtiring it tcr pay.twe5 upon t&e fullvalue 0r its proparty, but in denying to it the equality oi taxaticn se~u.ied,by the Constitution, which e+ality of s+-tioa necessarily depmds'upon uniforzity 0r asssssmnt. . .= Ordinarily the action of a board of equallzaticn upon a particular piece of'propertp is final, and a valilation will not b8 Set at3iES l?i8ZCu U?OE ShOVJinath.tlt it iS~8XO8SSiv8. BOWeaW , eilch eO8S not ho16 trU8 uhan such exoessi~e valuatitiaa is shown to result fron fraud on the part- of the board of equal- izatic?n,.or iron ah arbitrary or fuadamntolly wohg n&hod of, SSS8SSU8nt. Liv.alg vs. Fly, supra; Stats vs. Mallet Iand am5 Cattlc Co., .SD 3,i;;i(2) 4711 aowland vs. Cfty of~Tyler, 5 S.::. (2) 756; T. d; Fe By. CO. vii, xi hS0, a5 se%; (2) 245; &?8d8C (&) e.7;. X!r;eaC~w land Ind. School Dist. vs. Carter, 93 S~.k'.. VS. i%8r, is29 %%i, 493. 'Zn the ease d&h &I.% sub&i t3 us, the taxpayer ?cas oonplying with the statute in rendering his 3rogerty. Ee sha;lld not be discouraged Crmi dshg t!mi. In &dVbg the totuFtlVitLU8 andzaking oath to it he sas oniy swasriag to the truth. ii8 should not be penalized for that. 1Z8 WnS 8ntitlGd to b31ieV8 that all. property would be assesseti at its, true valua, or ir otLer progmty vias to be daliberately swsssed at only a frao- tional part of’ its value tht his asssssma@i wml.~ bG reduced as p,rcvvidGdih titicle 72l.2. Xhothsr the iailuro to ditiinish tha valuation on his progorty ras intcntfonti or accidental, the 8ri'&Ct i3 th8 9338. Proportionally he is paying EO:D than tiiioe tha tax piti by thoso about bin. This violates Section 1 of hr- tic18 G of t&8 Sate Constitution requir9.n~;that tcration be epuai emi uniform. In oil,” opinion tho aotior? oz? the Eoard of Quallwtion was void as to this uan's aseassmnt. ti I;rusnCow vs. &&er, supra, the Suprema Court said: The decisions of the (State) Tax &arc! in thG imttcr of valuations are c_uasi judicial iu their nature. This notion (to enjoti collecti of tax ,is th8Tefore & collateral attack u>oa the jucgmnt or a ;ua~si judicial ixibunaf. Such an attack cmatt bc Jus;tificd in the nbsenoc of fraud, f Eonorable George B. Sheppard, Page 4 or something equfvalent thereto; lack of jurisdfo- tioo; ah obvious violation of the law, or the ado?;. tion of a funmentally wrong principle or nethod, the application of uhich substactially injures cost-', p1abult.= The comnissioners* court sitting as a board of equal- ization is acting in a slm.Uar casoity to that or the state Tax Board, end if the decision of the one is quasi judicial in nature 50 is that of the other. See C. C. &S. F. 83. Co. vs. atate, 9 5. 3. (2), 1051, at p. 1052, so indicating. Our courts ,have frequently granted lnjunctioas to prevent the ool- lection of axoessive taxes,where such exoessivesess is a result of the adoption of a fundmentally wrong nethod of assessmnt or of fraud or other arbitrary action on tha part &the board of equalization. This oan only Eean that assess- ments whioh are excessive by reason of such situations are. VOld. fn our opi.nion, the 1954 aesessmmt described above vzasvoid end reassessment xzay be had as provided in Chapter 11, Title 122, Revised Civil Statutes. Bearlag an the question we %ould also cite the cases of State vs. Houser, L37 S.‘J;.(2) 800, French Independent School Dist, vs Bowth, 134 9.3. (2):1036, and C&I& S.F. By. Co. vs. state, 9 S.U. (2) 1051. ~'. B3b4L: Glen B, Lewis Assistant /ATTORNEY GEIUSRAL OF 'i-s?.\:::