Heritage Operating, L.P. v. Barbers Hill Independent School District

OPINION ON REHEARING

Tracy Christopher, Justice

We grant appellant’s motion for rehearing, withdraw our memorandum opinion issued July 2, 2015, and issue this opinion on rehearing.

In this suit to collect delinquent taxes for the 2004 tax year, the property owner both defended and counterclaimed on the ground that its personal property, which initially was omitted from the 2004 appraisal roll, was not added to the appraisal records within two years, and thus, the assessment is void. The taxing authorities responded that the property owner’s failure to exhaust its administrative remedies under…