Opinion No.

Office of the Attorney General — State of Texas John Cornyn The Honorable Pat Phelan Hockley County Attorney 802 Houston, Suite 211 Levelland, Texas 79336 The Honorable G. Dwayne Pruitt Terry County Attorney 500 West Main, Room 208E Brownfield, Texas 79316-4335

Re: The ad valorem taxation of mineral interests that extend across the boundary between two counties (RQ-0389-JC)

Gentlemen:

You ask about the proper method for allocating the taxable value of mineral interests that straddle the boundary between your two counties.1 While the Tax Code does not address this situation directly, we conclude…