Gifford-Hill & Co., Inc. v. Wise County Appraisal Dist.

OPINION

HIGHTOWER, Justice.

This is an ad valorem tax case. It involves the assessment of ad valorem taxes against limestone rock and the surface above the rock, and addresses whether limestone is a “mineral in place” or a “mine or quarry” under the Texas Tax Code. In 1987, Wise County Appraisal District created a new category of taxable property entitled “rock reserve” by separating the value of Gifford-Hill & Company, Inc.’s limestone from the value of its surface which qualified as “open-space” land. The surface was appraised based upon its productive capacity as agricultural land; however,…