Universal Underwriters Insurance Co. v. State

JONES, Justice.

In this tax protest suit, appellant Universal Underwriters Insurance Company (“Universal”) appeals from a summary judgment in favor of the State of Texas and other statutory defendants.1 In a single point of error, Universal contends that the trial court erred because, as a matter of law, a note and unrecorded Kansas real estate mortgage differs in character from an identical note and unrecorded mortgage on Texas real estate. We will affirm.

FACTUAL AND PROCEDURAL BACKGROUND

The Texas Insurance Code requires insurance companies, like Universal, to pay a gross premiums tax.…