Harris County Appraisal District v. ETC Marketing, LTD.

OPINION

TRACY CHRISTOPHER, Justice.

In the dispositive issue in this ad valo-rem tax-protest case, we conclude that a taxpayer desiring to have its property removed from the tax rolls on the ground that the property is in interstate commerce and therefore is exempt from taxation must exhaust administrative remedies by raising that argument with the appraisal review board in a timely tax protest under Chapter 41 of the Texas Tax Code. We therefore reverse the trial court’s rulings denying the appraisal district’s partial plea to the jurisdiction and granting the taxpayer’s motion for summary…