Opinion No.

The Honorable John Mann District Attorney 31st 223rd Judicial Districts of Texas P.O. Box 24 Shamrock, Texas 79079-0024

Re: Whether a school district is entitled to assess ad valorem taxes against royalty interests in a pooled gas unit based upon the location of the well or based upon the location of the real property to which the royalty interests appertain (RQ-1140)

Dear Mr. Mann:

The former Wheeler County Attorney1 submitted an opinion request to this office asking about the distribution of ad valorem taxes on royalty interests in gas between two school districts when the well is located in…