Houston Lighting & Power Co. v. Dickinson Independent School District

OPINION ON MOTION FOR REHEARING

BLEIL, Justice.

On motion for rehearing, the taxing units complain that we erred by rendering judgment assessing the 1981 value of HL & P’s property at $147,363,600.00, when our only authority is to set aside the assessment. Further, they contend that we erred by taxing costs against them. We agree that we so erred and reform our judgment accordingly.

The 1981 property assessment is not governed by the Texas Tax Code. Before 1982, the judicial relief available for an invalid property assessment was cancellation of the assessment without prejudice to the right of…