Bullock v. Ramada Texas, Inc.

PHILLIPS, Chief Justice.

Appellee sued appellants for recovery of $21,811.83 in franchise taxes, penalties and interest paid under protest, pursuant to Article 1.05, Title 122A, V.C.S. (1969).

*401The facts hereto were stipulated and the court, sitting without a jury, rendered judgment for appellee. Subsequently, appellants perfected their appeal to this Court.

We affirm.

The question before us is whether the trial court was in error in holding that only property owned by appellee on January 1, 1973, is to be included in computing appel-lee’s franchise tax under Article 12.01(l)(b), Title 122A,…